Accounting Period Ending: December 31
Foundation Status Classification: 509 (a) (1)
Advance Ruling Period Begins: May 3, 2000
Advance Ruling Period Ends: December 31, 2004
Addendum Applies: No
Dear
Applicant:
Based on information you supplied, and assuming your operations will be
as stated in your application for recognition of exemption, we have determined
you are exempt from federal income tax under section 501 (a) of the Internal
Revenue Code as an organization described in section 501(c)(3).
Because you are a newly created organization, we are not now making a
final determination of your foundation status under section 509 (a) of the
Code. However, we have determined that you can reasonably expect to be a publicly
supported organization described in sections 509(a)(1) and 170(b)(1)(A)(vi).
Accordingly, during an advance ruling period you will be treated as a
publicly supported organization, and not as a private foundation. This advance
ruling period begins and ends on the dates shown above.
Within 90 days after the end of your advance ruling period, you must send
us the information needed to determine whether you have met the requirements
of the applicable support test during the advance ruling period. If you establish
that you have been a publicly supported organization, we will classify you
as a section 509(a)(1) or 509(a)(2) organization as long as you continue to
meet the requirements of the applicable support test. If you do not meet the
public support requirements during the advance ruling period, we will classify
you as a private foundation for future periods. Also, if we classify you as
a private foundation, we will treat you as a private foundation from your
beginning date for purposes of section 507(d) and 4940.
Grantors
and contributors may rely on our determination that you are not a private
foundation until 90 days after the end of your advance ruling period. If you
send us the required information within the 90 days, grantors and contributors
may continue to rely on the advance determination until we make