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to petitioner, this "shows a great likelihood that the
degree of attentiveness * * * required by the regulation
will be present." Petitioner also argues that Keswick's
correspondence shows its "attentiveness to and reliance
upon the supporting organization". Lastly, petitioner
points out that under section 6104(d) Keswick is entitled
to obtain a copy of petitioner's annual return, which shows
a detailed listing of all of petitioner's investments and
its investment return.
Respondent's position is that petitioner is not a
supporting organization because it has not shown that it
has a relationship with Keswick or any other publicly
supported organization described by section 509(a)(3)(B).
Specifically, respondent contends that petitioner is not
"operated in connection with" Keswick or any other publicly
supported organization because petitioner does not meet
the "integral part test" described by section 1.509(a)-
4(i)(3)(iii), Income Tax Regs.
Respondent agrees that petitioner's support is
earmarked for a particular program or activity of Keswick,
raising a question whether the exception for earmarked
funds, section 1.509(a)-4(i)(3)(iii)(b), Income Tax Regs.,
is applicable. Contrary to petitioner's contention,
respondent argues that petitioner has not made the showing,
required under section 1.509(a)-4(i)(3)(iii)(b), Income Tax
Regs., that Keswick would be sufficiently attentive to the
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