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§ 3.4 PUBLIC CHARITIES AND PRIVATE FOUNDATIONSdonor during the computation period does not exceed an amount equal to 2 percentof the organization’s total support for the period. 383 Therefore, the totalamount of support by a donor is included in full in the denominator of the supportfraction and the amount determined by application of the 2 percent limitationis included in the numerator of the support fraction. The latter amount isthe amount of support in the form of direct or indirect contributions from thegeneral public. Donors who stand in a defined relationship to one another 384must share a single 2 percent limitation.This 2 percent limitation does not, however, generally apply to supportreceived from other publicly supported organizations of the donative type, norto grant support from governmental units. Thus, these types of support are, intheir entirety, public support, as indirect contributions from the general public.385 Because a charitable organization can be classified as not being a privatefoundation pursuant to a categorization other than a donative-type publiclysupported organization (such as by being one of the institutions), 386 and nonethelessmeet the requirements to be a donative-type publicly supported organization,387 the 2 percent limitation does not apply with respect to contributionsfrom these organizations. For example, financial support from a church is generallyconsidered to be indirect public support in full, because churches derivesubstantial amounts of their support from the general public, even though theirnon-private foundation status is derived, as discussed, 388 from their institutionalstatus as churches. 389 Nonetheless, the 2 percent limitation will apply withrespect to support received from a donative-type publicly supported organizationor governmental unit if the support represents an amount that wasexpressly or implicitly earmarked by a donor to the publicly supported organizationor unit of government as being for, or for the benefit of, the organizationasserting status as a donative-type publicly supported organization. 390In constructing the support fraction, an organization must exclude fromboth the numerator and the denominator of the support fraction amountsreceived from the exercise or performance of its exempt purpose or function andcontributions of services for which a charitable deduction is not allowable. 391 Anorganization will not be treated as meeting the support test, however, if itreceives almost all of its support from gross receipts from related activities andan insignificant amount of its support from the general public (directly and indirectly)and governmental units. 392 The organization may exclude from both thenumerator and denominator of the support fraction an amount equal to one ormore unusual grants. 393383 Reg. § 1.170A-9(e)(6)(i).384 IRC § 4946(a)(1).385 Reg. § 1.170A-9(e)(6)(i).386 See § 3.4(a), text accompanied by notes 344–377.387 Rev. Rul. 76-416, 1976-2 C.B. 57.388 See § 3.4(a), text accompanied by notes 344–346.389 Rev. Rul. 78-95, 1978-1 C.B. 71.390 Reg. § 1.170A-9(e)(6)(v).391 Reg. § 1.170A-9(e)(7)(i).392 Reg. § 1.170A-9(e)(7)(ii).393 Reg. § 1.170A-9(e)(6)(ii). See, e.g., Rev. Rul. 76-440, 1976-2 C.B. 58. 109