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involvement in the operations of one or more publicly
supported organizations and that such publicly supported
organizations are in turn dependent upon the supporting
organization for the type of support which it provides.
See sec. 1.509(a)-4(i)(3)(i), Income Tax Regs. In
effect, the integral part test ensures that the supported
organization will have the motivation to be attentive to
the activities of the supporting organization. See
Callahan Scholarship Fund v. Commissioner, 73 T.C. at 638.
There are two alternate ways to satisfy the integral
part test. Section 1.509(a)-4(i)(3)(ii), Income Tax Regs.,
describes the first method as follows:
(ii) The activities engaged in for or on behalf
of the publicly supported organizations are
activities to perform the functions of, or to
carry out the purposes of, such organizations,
and, but for the involvement of the supporting
organization, would normally be engaged in by
the publicly supported organizations themselves.
Thus, under this first method, the supporting organization
must actually engage in activities for or on behalf of the
publicly supported organization.
Petitioner does not engage in any activities on behalf
of Keswick, other than distributing funds to Keswick, and,
thus, does not claim to satisfy the first method of
complying with the integral part test, as described by
section 1.509(a)-4(i)(3)(ii), Income Tax Regs.
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