Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 35




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             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.                                 




















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