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(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 significant
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