and its equipment, granting
facts in its case if it receives at least
10% of its support from the general
scholarships and student loans, and
Gifts, grants & contributions . . $300,000
public. If the organization believes it is
making any other payments in
Gross receipts from
publicly supported according to
connection with the normal functions of
admissions, etc. . . . . . . . . . .
applicable regulations, attach a detailed
colleges and universities.
Dividends & interest . . . . . . .
statement of the facts upon which the
The organization must meet
organization bases its conclusion.
Line 23 minus line 17 . . . . . . .
essentially the same public support test
Line 12. Organization Meeting the
26a 2% of line 24 (2% limitation) . .
described below for line 11. See Rev.
Section 509(a)(2) Public Support
b Total of contributions
Rul. 82-132, 1982-2 C.B. 107.
Tests. Check the box on line 12 and
exceeding the 2% limitation . .
complete the Support Schedule to
Line 11. Organization Meeting the
determine whether an organization
The X organization determined
Section 509(a)(1) Public Support
meets both of the following section
whether or not it met the section
Test. Check either box (but not both)
509(a)(2) support tests:
on line 11a or 11b and complete the
support test as follows:
1. The organization normally
Support Schedule to determine whether
receives more than one-third of its
the organization meets the section
Total support (line 24): . . . . . . . . . $600,000
support for each tax year from:
a. Persons other than disqualified
support test described below.
persons (see Part IV, Definitions) with
Total direct contributions from
The Support Schedule is completed
respect to the organization,
persons who contributed less than
for an organization that normally (see
2% of total support . . . . . . . . . . . .
b. Governmental units (described in
section 170(c)(1)), or
Part IV, Definitions) receives at least
Total direct contributions from six
c. Organizations described in
% of its support (excluding income
donors, each of whom gave more
section 170(b)(1)(A) (other than in
received in exercising its charitable,
than 2% ($12,000) of total support
clauses (vii) and (viii)), and such
etc., function) from:
Indirect contributions from the
support is received by the organization
Direct or indirect contributions from
from any combination of:
the general public;
United Fund . . . . . . . . . . . . . . . .
Gifts, grants, contributions, or
Other publicly supported (section
membership fees, and
Grant from Y City . . . . . . . . . . . . .
170(b)(1)(A)(vi)) organizations; or
Gross receipts from admissions,
Total gifts, grants & contributions . . $300,000
A governmental unit.
sales of merchandise, performance of
Total direct contributions
services, or furnishing of facilities, in an
To determine whether the section
from six donors, each of
activity that is not an unrelated trade or
509(a)(1)/170(b)(1)(A)(vi) test is met,
whom gave more than 2%
business (within the meaning of section
of total support . . . . . . . $170,000
donor contributions are considered
support from direct or indirect
2% limitation for six
Gross receipts, in any tax year, do
contributions from the general public
not include receipts from any person,
(2% × $600,000 × 6) . . . .
only to the extent that the total amount
bureau, or similar agency of a
received from any one donor during the
government unit (described in section
Less: Direct contributions in excess
4-tax-year period is 2% or less of the
of 2% of total support . . . . . . . . . .
170(c)(1)) to the extent such receipts
organization’s total support for those 4
exceed the greater of $5,000 or 1% of
Total public support . . . . . . . . . . .
tax years as described below.
the organization’s support in such tax
Any contribution by one individual will
2. The organization normally
be included in full in the total support
Line 26c Total support . . . . . . . . $600,000
receives not more than one-third of its
denominator of the fraction determining
support each tax year from the sum of:
%-of-support or the
Line 26d Less total of lines:
18 . . . . $300,000
a. Gross investment income (as
19 . . . .
defined in section 509(e)), and
Only the portion of each donor’s
22 . . . .
b. The excess (if any) of the amount
contribution that is 2% or less of the
26b . . .
of the unrelated business taxable
total support denominator will be
income (as defined in section 512) over
Line 26e Total public support . . . . $202,000
included in the numerator.
the amount of the tax imposed by
Line 26f Public support
In applying the 2% limitation, all
percentage (line 26e
contributions by any person(s) related
divided by line 26c —
to the donor as described in section
Gross investment income. When
$202,000/ $600,000) . . .
4946(a)(1)(C) through (G) (and related
determining whether an organization
regulations) will be treated as if made
Since X organization received more
meets the gross investment income test
by the donor.
% of its total support for the
of section 509(a)(2)(B), amounts
period from public sources, it qualifies
The 2% limitation does not apply to
received from the following
as a section 509(a)(1)/170(b)(1)(A)(vi)
support from governmental units
organizations retain the character of
publicly supported organization. Note
referred to in section 170(c)(1), or to
gross investment income (rather than
that if an organization fails the public
contributions from publicly supported
gifts or contributions) to the extent that
support test for 2 consecutive years, it
organizations (section 170(b)(1)(A)(vi)),
these organizations characterize the
loses its public charity status and
that check the box on their line 11a or
amounts as gross investment income:
becomes a private foundation.
An organization that claims to be
Facts and circumstances — Public
described in section 509(a)(3) because
Example. X organization reported
support test. An organization that
it supports a section 509(a)(2)
the following amounts in its Support
does not qualify as publicly supported
Schedule for the 4-year period 2003
under the test described above may be
A charitable trust, corporation, fund,
publicly supported on the basis of the
or association described in section
Instructions for Schedule A (Form 990 or 990-EZ)