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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 the
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