- 35 -
were to satisfy the tests of the latter two provisions, as to
which we express no opinion, its failure to meet the requirements
of section 509(a)(3)(B) is fatal to its position that it is a
supporting organization and not a private foundation as defined
in section 509. In summary then, we hold that petitioner is to
be classified as a private foundation on account of failure to
satisfy the integral part test of section 1.509(a)-4(i)(3),
Income Tax Regs., as delineated above.
To reflect the foregoing,
Decision will be entered
for respondent.
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