Lapham Foundation, Inc. - Page 28




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          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.                                 







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