- 35 - petitioner. Finally, we disagree with petitioner's suggestion that attentiveness is demonstrated by the fact that petitioner is required by section 6104(d) to make available for inspection by any individual its annual tax return and certain other information, such as investment return and a listing of all investments. In this case, there is no evidence that Keswick exercised actual attentiveness to petitioner's operations. For the reasons discussed above, we affirm respondent's determination that petitioner fails to satisfy the attentiveness prong of the integral part test of section 1.509(a)-4(i)(3), Income Tax Regs., and that petitioner does not qualify to be excepted from private foundation status under section 509(a)(3). Decision will be entered for respondent.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35
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