FRATERNITY OF PHI GAMMA DELTA LANDMARK PRESERVATION INC

MAINTAINED, PRESERVED, AND REHABILITATED A REGISTERED LANDMARK, NAMELY THE PHI GAMMA DELTA HOUSE IN MADISON, WISCONSIN. EXPENDITURES INCLUDE COSTS OF MAINTENANCE, COSTS OF OWNERSHIP (E.G. INTEREST ON MORTGAGE), COSTS OF PROVIDING THE BUILDING FOR RENT TO TENANTS, AND COSTS OF REHABILITATION AND PRESERVATION. THE HOUSE IS RENTED TO INDIVIDUAL MEMBERS OF A FRATERNITY, WHO EACH PAY RENT TO THE ORGANIZATION. THE HOUSE WAS DESIGNATED AS A LANDMARK BY THE CITY OF MADISON (WISCONSIN) LANDMARK COMMISSION IN 1983, AND IS A PART OF THE LANGDON STREET HISTORIC DISTRICT, WHICH WAS ADDED TO THE NATIONAL REGISTER OF HISTORIC PLACES IN 1986. THE BUILDING WAS DESIGNED AND BUILT TO BE USED AS A FRATERNITY HOUSE. IF THE BUILDING IS NOT USED AS A FRATERNITY HOUSE, IT IS USELESS AND WOULD BE TORN DOWN. THE LOT IS LONG AND NARROW AND SLOPES STEEPLY TO THE LAKE THAT IS ADJACENT TO THE HISTORICAL DISTRICT. BECAUSE OF THE LOT'S DIMENSIONS, THE PROPERTY COULD NOT BE CONVERTED TO ANOTHER USE UNDER CURRENT ZONING ORDINANCES. THE INTERIOR LAYOUT OF THE HOUSE WAS DESIGNED BY FRANK LLOYD WRIGHT TO UNIQUELY SERVE THE BASIC FUNCTIONS OF FRATERNITY LIFE. ALTHOUGH THE BUILDING IS A HISTORIC LANDMARK AND ALWAYS AVAILABLE FOR PUBLIC VIEWING AND STUDY, IT IS NOT THE TYPE OF LANDMARK, LIKE LINCOLN'S HOME IN SPRINGFIELD FOR EXAMPLE, THAT ATTRACTS LARGE NUMBERS OF PAYING VISITORS THAT WOULD MAKE IT FEASIBLE TO OPERATE SOLELY AS A PUBLIC ATTRACTION. AS A RESULT OF THE FOREGOING CONSIDERATIONS, MAINTAINING THE BUILDING AS AN OPERATING FRATERNITY HOUSE RENTED TO FRATERNITY MEMBERS IS AN ESSENTIAL PART OF THE ORGANIZATION'S EXEMPT PURPOSE OF PRESERVING THE BUILDING AS A HISTORIC LANDMARK. RENTAL INCOME IS THEREFORE NOT INCOME FROM AN INVESTMENT, BUT RATHER INCOME DERIVED FROM THE ORGANIZATION'S CONDUCT OF ITS EXEMPT PURPOSE.