Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 19




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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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