"We have taken the position of treating clinical trials as unrelated business
income. The IRS position is that you must "prove" that you are not acting as
a marketing arm of the company. For example the pharmaceutical sponsored
clinical trial is being conducted to "test" their product. Successful results
enhances their product for future sales, etc.  You are therefore, aiding the
marketing of the product.  It is this reasoning that has governed our
decision to teat such endeavors as unrelated business expense. It is also way
we are fairly rigid with our demands for indirect cost reimbursement from
these companies.

Carl Schneiderman