This letter is in response to your telephone request on January 20, 2000 for a copy of your organization's
determination letter. This letter will take the place of the copy you requested.

Our records indicate that a determination letter issued in August 1997 granted your organization exemption
from federal income tax under section 501 (c)(3) of the Internal Revenue Code. That letter is still in effect.

Based on information subsequently submitted, we classified yoUr organization as one that is not a private
foundation within the meaning of section 509(a) of the Code because it is an organization described in
section 509(a)(2).

This classification was based on the assumption that your organization's operations would continue as stated
in the application. If your organization's sources of support, or its character, method of operations, or
purposes have changed, please let us know so we can consider the effect of the change on the exempt
status and foundation status of your organization.

Your organization is required to file Form 990, Retum of Organization Exempt from Income Tax, only if its
gross receipts each year are normally more than $25,000. if a return is required, it must be filed by the 15th
day of the fifth month after the end of the organization's annual accounting period. The law imposes a
penalty of $20 a day, L'p to a maximum of $10,000, when a return is filed late, unless there is reasonable
cause for the delay.

All exempt organizations (unless specifically excluded) are liable for taxes under the Federal Insurance
Contributions Act (social security taxes) on remuneration of $100 or more paid to each empioyee during a
calendar year. Your organization is not liable for the tax imposed under the Federal Unemployment Tax Act
(FUTA).

Organizations that are not private foundations are not subject to the excise taxes under Chapter 42 of the
Code. However, these organizations are not automatically exempt from other federal excise taxes.

Donors may deduct contributions to your organization as provided in section 170 of the Code. Bequests,
legacies, devises, transfers, or gifts to your organization or for its use are deductible for federal estate and
gift tax purposes if they meet the applicable provisions of sections 2055, 2106, and 2522 of the Code.

Your organization is not required to file federal income tax retunns unless it is subject to the tax on unrelated
business income under section 511 of the Code. If your organization is subject to this tax, it must file an
income tax return on the Form 990-T, Exempt Organization Business Income Tax Return. In this ietter, we
are not determining whether any of your organization's present or proposed activities are unrelated trade or
business as defined in section 513 of the Code.

The law requires you to make your organization's annual return available for public inspection without charge
for three years after the due date of the return. You are aiso required to make available for public inspection
a copy of your organization's exemption application, any supporting documents and the exemption letter to
any individual who requests such documents in person or in writing. You can charge only a reasonable fee
for reproduction and actual postage costs for the copied materials. The law does not require you to provide
copie of public inspection documents that are widely available, such as by posting them on the Internet
(World Wide Web). You may be liable for a penalty of $20 a day for each day you do not make these
documents available for public inspection (up to a maximum of $10,000 in the case of an annual return).

Because this letter could help resolve any questions about your organization's exempt status and foundation
status, you should keep it with the organization's permanent records.

If you have any questions, please call us at the telephone number shown in the heading of this letter.

This letter affims your organization's exempt status.

Sincerely,

Robert C. Padilla

Manager, Customer Service
 
 
 

Dear Applicant:

This modifies our letter of the above date in which we stated that you would be treated as an organization that 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)(2).

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)(2) 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)(2) 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.

If you have any questions, please contact the person whose name and telephone number are shown above.