ORGANIZATION DENIED EXEMPT STATUS.

UIL Code: 501C.00-00

Dear * * *:

This is a final adverse determination as to your exempt status under section 501(c)(3) of the Internal Revenue Code. It is determined that you do not qualify as exempt from Federal income tax under Section 501(c)(3) of the Internal Revenue Code.

Our adverse determination was made for the following reason(s):

You have failed to establish that you are organized and operated exclusively for exempt purposes specified under Section 501(c)(3) of the Internal Revenue Code. More than an insubstantial part of your proposed activities are in furtherance of non-exempt purposes and benefit private interests. You are organized and operated primarily to serve private interests rather than public interests. Furthermore, your organizational structure provides a potential for inurement.

Contributions to your organization are not deductible under Code section 170. See Rev. Proc. 82-39, 1982-2 C.B. 759, for rules concerning the deduction of contributions made to your organization between July 10, 2003 and the date that public announcement is made in the Internal Revenue Bulletin, stating that contributions to your organization are no longer deductible.

You are required to file Federal income tax returns on the form indicated above. Processing of income tax returns and assessment of any taxes due will not be delayed in the event that you file a petition for declaratory judgment under Code section 7428.

If you decide to contest this determination under the declaratory judgment provisions of Code section 7428, a petition to the United States Tax Court, the United States Court of Claims, or the district court of the United States for the District of Columbia must be filed before the 91^st (ninety-first) day after the date this determination was mailed to you. Contact the clerk of the appropriate court for rules for filing petitions for declaratory judgment. To secure a petition form from the United States Tax Court, write to the United States Tax Court, 400 Second Street, N.W., Washington, D.C. 20217.

We will notify the appropriate State officials of this final adverse determination of your exempt status, as required by Code section 6104(c).

If you have any questions, please contact the person whose name and telephone number are shown in the heading of this letter.