Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 20




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             that the amount of support received by the publicly                      
             supported organization must represent a sufficient part                  
             of the total support of the department or school, rather                 
             than the total support of the entire organization.  Id.                  
                  Furthermore, the regulations provide that, even if                  
             the amount of support received by the publicly supported                 
             organization does not represent a sufficient part of the                 
             organization's total support, the support received by the                
             publicly supported organization nevertheless may be                      
             sufficient.  Sec. 1.509(a)-4(i)(3)(iii)(b), Income Tax                   
             Regs.  According to the regulations, this may be true                    
             if it can be demonstrated that the beneficiary organiza-                 
             tion will be attentive to the supporting organization "in                
             order to avoid the interruption of the carrying on of a                  
             particular function or activity", such as where the                      
             payments are earmarked for a particular program or activity              
             which may not be the primary program or activity of the                  
             beneficiary organization but is "a substantial one."  Id.                
                  Finally, the regulations provide that all pertinent                 
             factors will be considered in determining whether the                    
             attentiveness prong is satisfied; that is, whether the                   
             amount of support received by a publicly supported                       
             organization is sufficient to ensure the attentiveness                   
             of that organization to the operations of the supporting                 
             organization.  See sec. 1.509(a)-4(i)(3)(iii)(d), Income                 
             Tax Regs.  The pertinent factors enumerated by the                       





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