In what is apparently the first court case on record attempting to apply unrelated business income tax (“UBIT”) rules to a 501(c)(4) social welfare organization, the Fourth Circuit Court of Appeals has affirmed a Tax Court decision that net income from parking lots and a beach club of a 501(c)(4) community association are subject to UBIT. The Ocean Pines Association in Maryland enforces zoning restrictions, maintains roads and parking lots, and operates recreational facilities in the Ocean Pines subdivision that had 10,496 residents in the 2000 Census. All of its programs and facilities are open to owners of residential property in the subdivision, who are the members of the association,...