- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011