- 28 - IV. Integral Part Test The complementary and interrelated roles of the responsiveness and integral part tests have been expressed by this Court as follows: While the responsiveness test guarantees that the supported organization will have the ability to influence the supporting organization’s activities, the integral part test insures that the supported organization will have the motivation to do so. The general thrust of this regulation is that the supporting organization must maintain a significant involvement in the operations of the supported organization so that the latter will be attentive to the supporting organization’s operations. [Nellie Callahan Scholarship Fund v. Commissioner, 73 T.C. at 637-638.] As previously discussed, the regulations in section 1.509(a)-4(i)(3), Income Tax Regs., offer two alternative sets of criteria for satisfying the integral part test, which we for convenience refer to as the “but-for subtest” of subdivision (ii) and the “attentiveness subtest” of subdivision (iii). A. But-For Subtest The but-for subtest will be met where: (1) The activities engaged in for or on behalf of the supported organization are activities to perform the functions of or to carry out the purposes of the supported organization, and (2) but for the involvement of the supporting entity, such activities would normally be engaged in by the supported organization itself. Sec. 1.509(a)-4(i)(3)(ii), Income Tax Regs.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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