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the program would not be interrupted or discontinued.
Respondent also argues, on the basis of the examples
set forth in section 1.509(a)-4(i)(3)(iii)(c), Income Tax
Regs., that the term "interruption" in section 1.509(a)-
4(i)(3)(iii)(b), Income Tax Regs., should be interpreted
to mean discontinuance. In effect, respondent argues that
a publicly supported organization will not be attentive to
the operations of the supporting organization unless the
loss of support from that organization will cause the
discontinuance of a particular program or activity, rather
than causing the program to be conducted in a different
manner or degree.
The dispute between the parties in this case involves
the question whether it is demonstrated in the administra-
tive record "that in order to avoid the interruption of
the carrying on of a particular function or activity,
the beneficiary organization [i.e. Keswick] will be
sufficiently attentive to the operations of the support-
ing organization [i.e. petitioner]." See sec. 1.509(a)-
4(i)(3)(iii)(b), Income Tax Regs. It also involves whether
the particular program or activity for which the support is
earmarked is a "substantial" program or activity. See id.
While the parties agree that petitioner's support to
Keswick is earmarked, they disagree about whether the
support is earmarked for the adult daycare program or for a
program to provide grants to needy participants in that
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