- 22 - of service to at least one half of needy grant recipients, the ultimate beneficiaries served. Thus, petitioner bases its argument that Keswick will be sufficiently attentive to petitioner's operations in order to prevent an "interruption" in the grant program on the fact that it contributes 50 percent of the discount offered by Keswick to certain participants in the daycare program and on the supposition that 50 percent of those recipients would be unable to participate in the program if petitioner's funds were not available. In this connection, petitioner argues that the term "interruption", simply means conducting the program in a different manner or degree rather than a complete cessation of the program. Petitioner also argues that the grant program "is certainly substantial in relation to the adult day care program." In this connection, petitioner points out that, of the 139 individuals who were served in the adult daycare program in 1999, "22% received grants". Petitioner also points out that the amount contributed in 1999 was $27,236, "not an unsubstantial sum". Finally, petitioner argues that the factors for determining attentiveness which are enumerated in section 1.509(a)-4(i)(3)(iii)(d), Income Tax Regs., weigh heavily in its favor. Petitioner points out that it has made distributions to Keswick for 7 years and that such distributions provide 50 percent of all grants. AccordingPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011