34.a.For an organization to qualify as receiving broad public support, both the external support test and the internal support test must be satisfied.

The total support received by Pigeon is 310,800. For purposes of the external support (more than one-third support) test, the following amounts are included.

Governmental unit A for services rendered (limited to) 6,300

Governmental unit B for services rendered4,500

General public for services rendered75,000

Contributions from other than disqualified persons 160,000

Qualifying support245,800

Therefore, the external support test is satisfied (245,800 310,800 79.0%).

For purposes of the internal support (not more than one-third support) test, only the gross investment income of 39,000 is within the limited categories....