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of the Board of Directors shall be appointed by the Board of
Directors of the publicly supported organization(s) for whose
benefit the Corporation exists.” We are satisfied that
petitioner is in conformity with section 1.509(a)-4(i)(2)(ii)(a),
Income Tax Regs.
Subdivision (d) of 1.509(a)-4(i)(2)(ii), Income Tax Regs.,
then requires that, by reason of the above relationship, the
supported organization have a “significant voice” in the
investment policies of the supporting organization; in the
timing, manner, and recipients of grants made by the supporting
organization; and in otherwise directing the use of the income or
assets of the supporting organization. The term “significant” in
this context has been interpreted to mean “‘likely to have
influence,’ not control.” Cockerline Meml. Fund v. Commissioner,
supra at 60 (quoting Webster’s Third New International Dictionary
2116 (1981)); see also Roe Found. Charitable Trust v.
Commissioner, supra.
Respondent by answer raised the issue of failure to satisfy
the responsiveness test, alleging therein that the director
appointed by AEF lacked a significant voice in the activities
specified in section 1.509(a)-4(i)(2)(ii)(d), Income Tax Regs.
On brief respondent argues that no facts have been given to show
Mr. Gallina will have a significant voice in determining
petitioner’s investment policies or when and where petitioner’s
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