My organization is a public charity under sections 509(a)(1) and 170(b)(1)(A)(vi) of the Code, and it received 15 percent of its support from the general public. Because my organization received less than 33-1/3 percent of its support from the general public, how do I show the IRS on the Schedule A that it meets the facts and circumstances test?
If your organization receives more than 10 percent but less than 33-1/3 percent of its support from the general public or a governmental unit, it can qualify as a public charity if it can establish that, under all the facts and circumstances, it normally receives a substantial part of its support from governmental units or the general public. To establish this support, your organization should describe on Part VI of Schedule A the facts and circumstances which establish that the organization is in the nature of an organization that is publicly supported. Regulations section 1.170A-9(f)(3) discusses pertinent facts and circumstances.