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§ 3.4 PUBLIC CHARITIES AND PRIVATE FOUNDATIONSinclude convalescent homes, homes for children or the elderly, or institutions theprincipal purpose or function of which is to train handicapped individuals topursue a vocation, 363 nor does it include free clinics for animals. 364For these purposes, the term medical care includes the treatment of any physicalor mental disability or condition, whether on an inpatient or outpatient basis,provided the cost of the treatment is deductible 365 by the individual treated. 366Thus, to avoid private foundation status as a hospital, the organizationmust be more than an organization that generally engages in activities that promotehealth. 367MEDICAL RESEARCH ORGANIZATIONSA medical research organization is a public charitable organization and thus is not aprivate foundation. 368 It is an organization “directly engaged in the continuousactive conduct of medical research in conjunction with a hospital.” 369 The organizationneed not be formally affiliated with a hospital to be considered primarilyengaged in the active conduct of medical research in conjunction with ahospital. There must, however, be a joint effort on the part of the research organizationand one or more hospitals pursuant to an understanding that the organizationswill maintain continuing close cooperation in the active conduct ofmedical research. 370The term medical research means the conduct of investigations, experiments,and studies to discover, develop, or verify knowledge relating to the causes,diagnosis, treatment, prevention, or control of physical or mental diseases andimpairments of human beings. To qualify, the organization must have the appropriateequipment and professional personnel necessary to carry out its principalfunction. 371 Medical research encompasses the associated disciplines spanningthe biological, social, and behavioral sciences. 372CERTAIN SUPPORTING FOUNDATIONSCertain supporting foundations are public charitable organizations and thus arenot private foundations. These organizations are foundations that provide supportfor colleges and universities that are administered by governments. 373The organization must normally receive a substantial part of its support(exclusive of income received in the exercise or performance of its tax-exemptactivities) from the United States or from direct or indirect contributions fromthe general public. It must be organized and operated exclusively to receive,363 Reg. § 1.170A-9(c)(1).364 Rev. Rul. 74-572, 1974-2 C.B. 82.365 IRC § 213.366 Reg. § 1.170A-9(c)(1). The rules concerning the tax qualification of hospitals are discussed in Tax-Exempt Organizations§§ 6.2 and 11.3.367 Organizations that generally promote health are discussed in Tax-Exempt Organizations § 6.2.368 IRC §§ 170(b)(1)(A)(iii) and 509(a)(1).369 IRC § 170(b)(1)(A)(iii).370 Reg. § 1.170A-9(c)(2)(vii).371 Reg. § 1.170A-9(c)(2)(iii).372 The rules concerning medical research organizations are discussed in Tax-Exempt Organizations § 11.3.373 IRC §§ 170(b)(1)(A)(iv) and 509(a)(1). 107