- 16 - (2) Responsiveness test. (i) For purposes of this paragraph, a supporting organization will be considered to meet the "responsiveness test" if the organization is responsive to the needs or demands of the publicly supported organizations within the meaning of this subparagraph. In order to meet this test, either subdivision (ii) or subdivision (iii) of this subparagraph must be satisfied. * * * * * * * (iii)(a) The supporting organization is a charitable trust under State law; (b) Each specified publicly supported organization is a named beneficiary under such charitable trust's governing instrument; and (c) The beneficiary organization has the power to enforce the trust and compel an accounting under State law. In this case, petitioner is a charitable trust under the law of the State of Maryland. Keswick, the publicly supported organization, is a named beneficiary under the second codicil, and it has the power to enforce the trust and compel an accounting under the law of the State of Maryland. See Md. Code Ann., Est. & Trusts, sec. 14-301 (2001). Thus, petitioner meets section 1.509(a)- 4(i)(2)(iii), Income Tax Regs., and, accordingly, meets the responsiveness test as to Keswick. See generally Callahan Scholarship Fund v. Commissioner, supra at 634- 637. Respondent does not contend otherwise. The integral part test, prescribed by section 1.509(a)-4(i)(3), Income Tax Regs., is designed to ensure that the supporting organization maintains a significantPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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