United Cancer Council, Inc. - Page 110

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               the activities of the organization.                                    
               See sec. 1.501(c)(3)-1(c)(2), Income Tax Regs.                         
          This definition is unchanged from Regs. 65, art. 517 (1924),                
          except that the older regulations use “individuals” and                     
          “corporation”, instead of “persons” and “organization”,                     
          respectively.  Art. 517 of Regs. 65 is essentially similar to               
          Regs. 45, art. 517 (1920).  In general, the case law appears to             
          have drawn a line between those who have significant control over           
          the organization’s activities and those who are unrelated third             
          parties.  People of God Community v. Commissioner, 75 T.C. 127,             
          133 (1980).                                                                 
               We proceed to consider whether, and if so then to what                 
          extent, W&H controlled petitioner’s activities.                             
               On the one hand, neither W&H nor Watson nor Hughey was a               
          director or officer of petitioner, nor did any of them have a               
          formal voice in the selection of any director or officer of                 
          petitioner.                                                                 
               On the other hand, in exchange for (a) funds to keep                   
          petitioner operational and get it past its 1984 financial crisis            
          and (b) fundraising services, W&H received (1) compensation, (2)            
          effectively exclusive control over petitioner’s fundraising                 
          activities, including supposedly separate computer activities,              
          and (3) substantial control over petitioner’s finances.  The                
          amounts that W&H would advance for petitioner’s operational costs           
          and as capital for petitioner’s fundraising costs were not                  




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