Lapham Foundation, Inc. - Page 17




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               the supporting organization, would normally be engaged                 
               in by the publicly supported organizations themselves.                 
               The second alternative (referred to as the “attentiveness              
          subtest”) is laid out in section 1.509(a)-4(i)(3)(iii), Income              
          Tax Regs.:                                                                  
                    (a) The supporting organization makes payments of                 
               substantially all of its income to or for the use of                   
               one or more publicly supported organizations, and the                  
               amount of support received by one or more of such                      
               publicly supported organizations is sufficient to                      
               insure the attentiveness of such organizations to the                  
               operations of the supporting organization.  In                         
               addition, a substantial amount of the total support of                 
               the supporting organization must go to those publicly                  
               supported organizations which meet the attentiveness                   
               requirement of this subdivision with respect to such                   
               supporting organization.  Except as provided in (b) of                 
               this subdivision, the amount of support received by a                  
               publicly supported organization must represent a                       
               sufficient part of the organization’s total support so                 
               as to insure such attentiveness.  In applying the                      
               preceding sentence, if such supporting organization                    
               makes payments to, or for the use of, a particular                     
               department or school of a university, hospital or                      
               church, the total support of the department or school                  
               shall be substituted for the total support of the                      
               beneficiary organization.                                              
                    (b) Even where the amount of support received by a                
               publicly supported beneficiary organization does not                   
               represent a sufficient part of the beneficiary                         
               organization’s total support, the amount of support                    
               received from a supporting organization may be                         
               sufficient to meet the requirements of this subdivision                
               if it can be demonstrated that in order to avoid the                   
               interruption of the carrying on of a particular                        
               function or activity, the beneficiary organization will                
               be sufficiently attentive to the operations of the                     
               supporting organization.  This may be the case where                   
               either the supporting organization or the beneficiary                  
               organization earmarks the support received from the                    
               supporting organization for a particular program or                    
               activity, even if such program or activity is not the                  






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