- 26 - program. They also disagree about the meaning of the term "interruption" as used in the regulation. Finally, they disagree about whether the adult daycare program or the grant program is a "substantial" program or activity of Keswick, as required by section 1.509(a)-4(i)(3)(iii)(b), Income Tax Regs. On the basis of our review of the administrative record, we do not believe that it has been demonstrated that Keswick will be sufficiently attentive to petitioner's operations in order to avoid an "interruption" of either the adult daycare program or a program to provide grants to needy participants in that program. Furthermore, while the daycare program with "Actual (Projected)" revenues of $640,775 and direct and indirect costs of $1,140,568 in fiscal year 2000 appears to be a substantial program, there is not sufficient information in the administrative record to make the same finding about the grant program. The information about Keswick in the administrative record of this case is sketchy. We know that Keswick conducts a domiciliary nursing care program which is its primary program or activity, and we know that it conducts a daycare program through its adult day services center. The record provides little or no specific information about the domiciliary program, such as how many individuals are served by the program, what services are provided to participants in the program, what revenues are realizedPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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