Internal Revenue Service
Department of the Treasury
G.P.O. Box 1680
Brooklyn, NY 11202
Date: February 14, 1999
c/o Charles K. Campbell
Cummings & Lockwood
2 Greenwich Plaza
Greenwich, CT 06830-0000
Employer Identification Number: 22-2577250
Contact Person: Joseph Wolf
Contact Telephone Number: (718) 780-4048
Our Letter Dated: April 26, 1985
Addendum Applies: no
This modifies our letter of the above date in which we stated that you would be treated as an organization which is not a private foundation until the expiration of your advance ruling period.
Your exempt status under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3) is still in effect. Based on the information you submitted, we have determined that you are not a private foundation within the meaning of section 509(a) of the code because you are an organization of the type described in section 509(a)(1) and 170(b)(1)(A)(vi).
Grantors and contributors may rely on this determination unless the Internal Revenue Service publishes notice to the contrary. However, if you lose your section 509(a)(1) status, a grantor or contributor may not rely on this determination if he or she was in part responsible for, or was aware of, the act or failure to act, or the substantial or material change on the part of the organization that resulted in your loss of such status, or if he or she acquired knowledge that the Internal Revenue Service had given notice that you would no longer be classified as a section 509(a)(1) organization.
If we have indicated in the heading of this letter that an addendum applies, the addendum enclosed is an integral part of this letter.
Because this letter could help resolve any questions about your private foundation status, please keep it in your permanent records.
We have sent a copy of this letter to your representative as indicated in your power of attorney.
If you have any questions, please contact the person whose name and telephone number are shown above.
Eugene D. Alexander
Eugene D. Alexander’s signature appears under his salutation.