> 2. It is regularly carried on - not really, there's only one .org domain so one can't regularly sell it. You're right. I misread #2 as the inverse so misund

> 2. It is regularly carried on - not really, there's only one .org domain so one can't regularly sell it. You're right. I misread #2 as the inverse so misunderstood what UBI was. > 3. It is not substantially related to furthering the exempt purpose of the organization - that one would be the toughest to prove... Kinda a moot point given #2, but the IRS elaborates (emphasis mine), "... only when the conduct of the business activities has causal relationship to achieving exempt purposes (_other than through the production of income_)"