- 9 - zation, thereby failing the "integral part test" set forth in the regulations. Consequently, your organization does not qualify as a supporting organization within the meaning of section 509(a)(3) of the Code. Petitioner's attorneys filed a letter with respondent's Office of Appeals appealing the proposed adverse ruling. In the letter, they state that petitioner's support is earmarked by the controlling document to provide "grants associated with Keswick's Adult Day Care Program", that petitioner "provides up to 50 percent of the grant money provided to 100 percent of all grant recipients", that the "Keswick Day Care Program is a substantial program providing day care for 139 adults within the Baltimore Metropolitan area", and "without the funds provided by the Cuddeback Memorial Fund, the grant program would be severely curtailed, and a significant number of individuals would be unable to receive financial assistance in connection with the Adult Day Care Program". The letter further states that, under section 1.509(a)- 4(i)(3)(iii)(b), Income Tax Regs., in determining the attentiveness of the beneficiary organization, "the total support for the day care grant program" is substituted for "the total support of the beneficiary organization." On that basis, petitioner's attorneys state "the attentivenessPage: 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