"Unrelated trade or business" is defined as (1) any trade or business (2) regularly carried on by the organization (3) the conduct of which is not substantially related (aside from the production of funds) to the organization's performance of its exempt functions.” [Henry E. & Nancy Horton Bartels Trust ex rel. Cornell Univ. v. United States, 2010 U.S. App. LEXIS 18678 (Fed. Cir. Sept. 7, 2010)].