Art Museum is a California nonprofit public benefit corporation with IRC Section
501(c)(3) tax-exempt status. It’s function is to educate the public by displaying works of
art for public appreciation. Art Museum would like to enter into a partnership agreement
with a for-profit art gallery to display works of local artists and then sell the works
through the gallery. Art Museum and the art gallery would share in a 50 percent
commission on sales. Explain how the partnership could jeopardize the tax-exempt status
of the museum. Also discuss whether the income from sale of the art would be subject to
the unrelated business income taxation.

