From time to time I have heard that the IRS has taken the position that
monies coming to an institution to support clinical trials (particular
Phase III trials) represent unrelated business income.  Indeed, at a recent
meeting in Clearwater, FL, it was stated that there is now an inspector
general's opinion to that effect.  Apparently, the logic is that clinical
trials (particularly Phase III trials) are TESTING, not RESEARCH and therefore
do not represent the business of most educational institutions (e.g.,
education, research and service).
 Does anyone have a copy of a written IRS or IG opinion that addresses
this issue or have additional information that might clarify the issue?
If so, I would certainly appreciate a copy.

 Thanks,     Doug

Doug Wilkerson, Ph.D.           VOICE:  (419) 381-4252
Assoc. V.P. for Research        FAX:    (419) 381-4262
Professor of Pharmacology       e-mail: xxxxxx@GEMINI.MCO.EDU
Medical College of Ohio
3000 Arlington Ave.
Toledo, OH 43614