OPINION
DIANA GRIBBON MOTZ, Circuit Judge:
The Tax Court determined that the net income from two parking lots and a beach club owned by a tax-exempt association constitutes "unrelated business taxable income." The association appeals. Because the income derived from the parking lots and beach club is not "substantially related" to the association's tax-exempt purpose, we affirm.
I.
Before the Tax Court, the parties stipulated to the facts...
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