Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 4




                                        - 4 -                                         
             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:                                            








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011