Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 17




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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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