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Church, Baltimore, Maryland (Parklane), and Keswick Multi-
Care Center, formerly known as the Keswick Home for the
Incurables of Baltimore City, Baltimore, Maryland,
(Keswick). Each of these recipients is a charitable
organization described in section 501(c)(3) and is
classified as other than a private foundation under
sections 509(a)(1) and 170(b)(1)(A)(i) or (iii). Such
organizations are sometimes referred to as "publicly
supported [organizations]". See sec. 1.509(a)-4(a)(5),
Income Tax Regs. Under the terms of the second codicil,
Bedford and Parklane are each to receive 10 percent of the
Cuddeback Fund's net income, and Keswick is to receive 80
percent of petitioner's net income at annual or more
frequent intervals.
Keswick's primary program or activity is providing
in-house, full-time nursing home care (domiciliary care).
Keswick also provides daycare to individuals through its
adult day services center or program. In conjunction with
this daycare program, Keswick offers "grants" to some
participants who could not otherwise afford to pay the full
amount that Keswick charges for its services.
With respect to Keswick, the second codicil provides
in pertinent part as follows:
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Last modified: May 25, 2011