- 20 - that the amount of support received by the publicly supported organization must represent a sufficient part of the total support of the department or school, rather than the total support of the entire organization. Id. Furthermore, the regulations provide that, even if the amount of support received by the publicly supported organization does not represent a sufficient part of the organization's total support, the support received by the publicly supported organization nevertheless may be sufficient. Sec. 1.509(a)-4(i)(3)(iii)(b), Income Tax Regs. According to the regulations, this may be true if it can be demonstrated that the beneficiary organiza- tion will be attentive to the supporting organization "in order to avoid the interruption of the carrying on of a particular function or activity", such as where the payments are earmarked for a particular program or activity which may not be the primary program or activity of the beneficiary organization but is "a substantial one." Id. Finally, the regulations provide that all pertinent factors will be considered in determining whether the attentiveness prong is satisfied; that is, whether the amount of support received by a publicly supported organization is sufficient to ensure the attentiveness of that organization to the operations of the supporting organization. See sec. 1.509(a)-4(i)(3)(iii)(d), Income Tax Regs. The pertinent factors enumerated by thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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