- 15 -
to qualify. See Quarrie Charitable Fund v. Commissioner,
supra at 1278 n.5; Roe Found. Charitable Trust v.
Commissioner, supra. Specifically, section 1.509(a)-4(i),
Income Tax Regs., provides the following guidance on how to
qualify as an "operated in connection with" organization:
(i) Meaning of "operated in connection with"--
(1) General rule. (i) Except as provided in
subdivisions (ii) and (iii) of this subpara-
graph and subparagraph (4) of this paragraph,
a supporting organization will be considered as
being operated in connection with one or more
publicly supported organizations only if it
meets the "responsiveness test" which is defined
in subparagraph (2) of this paragraph and the
"integral part test" which is defined in
subparagraph (3) of this paragraph.
Thus, in order to qualify as a supporting organization
under the "operated in connection with" relationship,
petitioner must satisfy both the responsiveness test and
the integral part test prescribed by the regulations.
The responsiveness test, prescribed by section
1.509(a)-4(i)(2), Income Tax Regs., is designed to ensure
that the publicly supported organization has the ability to
influence the activities of the supporting organization or
has the power to compel an accounting from the supporting
organization. See Cockerline Meml. Fund v. Commissioner,
supra at 59-60; Roe Found. Charitable Trust v.
Commissioner, supra. Section 1.509(a)- 4(i)(2), Income Tax
Regs., describes this test, in part, as follows:
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