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b. [[underline]] Federal Income Tax Status of the Institution [[/underline]]

The opinion prepared for the Institution by the firm of Cohen and Uretz concerning the tax exempt status of the Smithsonian under the basic provisions of its original statutory charter has now been redrafted to serve as a basis for discussion with the Office of Legal Counsel. As reported previously, the specific question involved is the applicability of the "unrelated business tax" in Section 511 of the Internal Revenue Code; but since the answer must be sought in the basic Smithsonian legislation rather than the tax law, it was decided to consult the Justice Department in the first instance. These discussions will be initiated in the next few weeks.