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(3) an organization which–-
(A) is organized, and at all times
thereafter is operated, exclusively for
the benefit of, to perform the func-
tions of, or to carry out the purposes
of one or more specified organizations
described in paragraph (1) or (2),
(B) is operated, supervised, or
controlled by or in connection with one
or more organizations, described in
paragraph (1) or (2), and
(C) is not controlled directly or
indirectly by one or more disqualified
persons (as defined in section 4946)
other than foundation managers and
other than one or more organizations
described in paragraph (1) or (2);
* * *
The above provision was "designed to insure that a
supported organization has the ability and motivation
to properly oversee the activities of the supporting
organization." Cockerline Meml. Fund v. Commissioner,
86 T.C. 53, 65 (1986).
Respondent's determination is based upon petitioner's
failure, as to each of the three recipients of Cuddeback
funds, to meet subparagraph (B) of section 509(a)(3), which
describes the nature and quality of the relationship that
must exist between the supporting organization and the
supported organization. See generally Quarrie Charitable
Fund v. Commissioner, 603 F.2d 1274, 1278 (7th Cir. 1979),
affg. 70 T.C. 182 (1978); Cockerline Meml. Fund v.
Commissioner, supra at 58; Callahan Scholarship Fund v.
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