- 14 - Commissioner, 73 T.C. 626, 632 (1980); Roe Found. Charitable Trust v. Commissioner, T.C. Memo. 1989-566. In order to satisfy section 509(a)(3)(B) the organization must be one which is: (1) Operated, supervised, or controlled by; (2) supervised or controlled in connection with; or (3) operated in connection with, one or more publicly supported beneficiary organizations. See sec. 1.509(a)-4(f)(2), Income Tax Regs. According to section 1.509(a)-4(f)(3), Income Tax Regs., any relationship described in section 509(a)(3)(B) must ensure that (i) The supporting organization will be respon- sive to the needs or demands of one or more publicly supported organizations; and (ii) The supporting organization will con- stitute an integral part of, or maintain a significant involvement in, the operations of one or more publicly supported organizations. Petitioner argues that it satisfies the third rela- tionship described by section 509(a)(3)(B), the "operated in connection with" relationship, as to Keswick. See generally sec. 1.509(a)-4(i), Income Tax Regs. Under this relationship, it is not necessary for one organization to control the other, or for a third party to control both, but it is necessary for there to be a sufficient connection between the two organizations. Because this is the least intimate of the three types of relationship, the regulation imposes a stringent two-part test that must be met in orderPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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