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support charities in Northville, Michigan, or southeastern
Michigan. However, as found above, AEF is not bound by such
recommendations and can use the support received from petitioner
to fund charitable activities anywhere in the United States.
AEF endeavors through its grant making to benefit
communities throughout the United States. Yet such grant-making
activities cannot properly be characterized as something in which
AEF would be engaged but for petitioner’s support. Rather,
distributing grant moneys is something in which AEF is and will
continue to be engaged regardless of support from petitioner.
Hence, the record reveals no but-for relationship between
petitioner’s operations and those of AEF and, accordingly, cannot
establish the type of dependency sought by the integral part
test.
B. Attentiveness Subtest
Under the attentiveness subtest, (1) the supporting
organization must make payments of substantially all of its
income to or for the use of the supported organization, and (2)
either (a) the amount of support must be sufficient to ensure the
attentiveness of the supported entity or (b) the funds must be
earmarked for a substantial program or activity of the supported
entity, such that the supported organization will be attentive to
avoid interruption thereof. Sec. 1.509(a)-4(i)(3)(iii)(a) and
(b), Income Tax Regs.
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