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activity so long as such program or activity is a
substantial one.
Thus, the supporting organization must satisfy three
criteria or prongs. First, the supporting organization
must make payments of substantially all its income to or
for the use of one or more publicly supported organiza-
tions. See sec. 1.509(a)-4(i)(3)(iii)(a), Income Tax Regs.
We refer to this as the substantially all prong. Second,
the amount of support received by one or more publicly
supported organizations must be "sufficient to insure the
attentiveness of such organizations to the operations of
the supporting organization". Id. We refer to this as
the attentiveness prong. Third, a substantial amount of
the total support of the supporting organization must go
to those publicly supported organizations which meet the
attentiveness prong with respect to the supporting
organization. Id. We refer to this as the substantial
amount prong.
In applying the attentiveness prong of the integral
part test, the regulations state that the amount of
support received by the publicly supported organization
must represent "a sufficient part" of the total support
received by the publicly supported organization. Id. In
making this determination, if the supporting organization
makes payments to a particular department or school of a
university, hospital, or church, the regulations provide
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