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             petitioner's funds.  Petitioner bases that assertion on                  
             Keswick's letter which states that of the 31 grants made in              
             1999, the first 50 percent of each grant is covered by                   
             Keswick and "the remaining 50 percent comes from Cuddeback               
             funds".  However, none of Keswick's letters states that                  
             petitioner provided 50 percent of all grants given by                    
             Keswick during the year or that petitioner provided 50                   
             percent of Keswick's charity care for the year.  To the                  
             contrary, as mentioned above, Keswick's letters state that               
             it had "other funding sources."  We do not know what other               
             funding sources Keswick had, and we do not know the full                 
             extent of Keswick's charity care.  Therefore, we cannot                  
             evaluate the relative importance of the funds provided by                
             petitioner or whether the loss of petitioner's funds would               
             cause an "interruption" of any kind in Keswick's grant                   
             program.                                                                 
                  Moreover, even if we were to accept petitioner's                    
             assertion that "50% of the total grants were supplied by                 
             Petitioner's distribution", we question whether that would               
             assure Keswick's "attentiveness".  Keswick's financial                   
             information for fiscal year 2000 shows that it sustained a               
             loss from the daycare program of $499,793 (gross revenue of              
             $640,775 less direct and indirect costs of $1,140,568).                  
             Thus, it appears that the $60 per day charge was well below              
             the cost of the program and is an artificial measure of the              
             importance of petitioner's support.  On the other hand, if               
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