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2508 CINCINNATI, OH 45201                                    Employer Identification Number: 30-
   Date: JAN 272003                                      DLN:                       17053324048042
                                                         Contact       Person:      JOSEPH       R
                                                         ID#                                 31128
c/o          RANDAL     C        TEAGUE
                                                         Contact Telephone Number: (877) 829-5500
                                                         Accounting period Ending: December 31
                                                         Form        990       Required:       Yes
                                                         Addendum Applies: No

 Dear Applicant:

     Based on information 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).

     We have further determined that you are not a private foundation within the meaning of section
 509(a) of the Code, because you are an organization descr!bed in section 509(a) (3).

     If your sources of support, or your purposes, character, or method of operation change, please
 let us know so we can consider the effect of the change on your exempt status and foundation
 status. In the case of an amendment to your organizational document or bylaws, please send us a
 copy of the amended document or bylaws. Also, you should inform us of all changes in your
 name or address. .

     As of January 1, 1984, you are liable for taxes under the Federal Insurance contributions Act
 (social security taxes) on remuneration of $100 or more you pay to each of your employees during a
 calendar year. You are not liable for the tax imposed under the Federal Unemployrnent Tax Act

     Since you are not a private foundation, you are not subject to the excise taxes under Chapter 42
 of     the      Codeo       However,      if     you      are     involved      in     an      excess
 benefit transaction, that transaction might be subject to the excise taxes of section 4958.
 Additionally, you are not automatically exempt from other federal excise taxes. If you have any
 questions about excise, employrnent, or other federal taxes, please contact your key district office.

      Grantors and contributors may rely on this determination unIess the Internal Revenue Service
 publishes notice to the contrary. However, if you lose your section 509(a) (3) 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

     Letter 947 (DO/CG)

    part of the organization that resulted in your los s 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) (3) organization.

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

     Contribution deductions are allowable to donors only to the extent that their contributions are
gifts, with no consideration received. Ticket purchases and similar payrnents in conjunction with
fundraising events may not necessarily qualify as deductible contributions, depending on the circum-
stances. See Revenue Ruling 67-246, published in Cumulative BUlletin 1967-2, on page 104, which
sets forth guidelines regarding the deductibility, as charitable contributlons, of payrnents made by
taxpayers for admission to or other participation in fundraising activities for charity.

    In the heading of this letter we have indicated whether you must file Form 990, Return of
Organization Exempt From Income Tax. If Yes is indicated, you are required to file Form 990 only if
your gross receipts each year are normally more than $25,000. However, if you receive a Form 990
package in the mall, please file the return even if you do not exceed the gross receipts test. If you
are not required to file, simply attach the label provided, check the box in the heading to indicate
that your annual gross receipts are normally $25,000 or less, and sign the return.

     If a return is required, it must be filed by the 15th day of the fifth month after the end of your
annual accounting periodo A penalty of $20 a day is charged when a return is filed late, unless there
is reasonable cause for the delay. However, the maximum penalty charged cannot exceed $10,000
5 percent of your gross receipts for the year, whichever is less. For organizations with grose receipts
exceeding $1,000,000 in any year, the penalty is $100 per day per return, unless there is reasonable
cause for the delay. The maximum penalty for an organization with gross receipts exceeding
$1,000,000 shall not exceed $50,000. This penalty may also be charged if a return is not complete,
so be sur e your return is complete before you file it.

    You are required to make your annual information return, Form 990 or Form 990-EZ, available
for public inspection for three years after the later of the due date of the return or the date the
return is filed. You are also required to make available for public inspection your exemption
application, any supporting documents, and your exemption letter. Copies of these documents are
also required to be provided to any individual upon written or in person request without charge
other than reasonable fees for copying and postage. You may fulfill this requirement by placing
these documents on the Internet. penalties may be imposed for failure to comply with these
requirements. Additional information is available in Publication 557, Tax-Exempt Status for Your
Organization,          or         you         may           call       our         toll        free
nwnber shown above.

    Letter 947 (DOjCG)

     You are not required to fiIe federal income tax returns unIese you are subject to the tax on
unreIated business income under section 511 of the Codeo If you are subject to this tax, you must
fiIe an income tax return on Form 990-T, Exempt organization Business Income Tax Return. In this
letter we are not determining whether any of your present or proposed activities are unreIated
trade      or     business     as     defined     in     section    513     of     the      Codeo

You need an empIoyer identification number even if you have no empIoyees. If an employer
identification number was not entered on your appIication, a number will be assigned to you and you
will be advised of it. Please use that number on all returns you file and in all correspondence with
the                          Internal                       Revenue                          Service.

This    determination     ie   based     on    evidence   that    your    funds    are     dedicated
to the purposes Iisted in section 501(c) (3) of the Codeo To assure your continued exemption, you
should keep records to show that funds are expended only for those purposes. If you distribute funds
to other organizations, your records should show whether they are exempt under section 501(c) (3).
In cases where the recipient organization is not exempt under section 501(c) (3), there should be
evidence that the funds will remain dedicated to the required purposes and that they will be used
for             those               purposes             by              the               recipient.

If we have indicated in the heading of this letter that an addendum applies, the encIosed addendum
is an integral part of this letter.

    Because thie letter could help resolve any questions about your exempt status and foundation
status, you should 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 in the heading of this letter.

                                                                             sincerely yours
                                                               Lois . Lerner Director, Exempt Organizations

                                                                       Letter 947 (DO/CG)
   Charitable Contributions
Substantiation and Disclosure
    UNDER THE NEW LA W, cilARITIEs WILL                  Picase note that tbere Is a De1\' law
NEED      TO    PROVIDE     NEW       KINDS   OF     requirinll     chartties        te        furnlsh
INFORMATION:I'O DONORS, Failure lo do so may         disdosarestatementl to donon for such quid pro
resull in denial of dcductions lo donors and !he     quo dOuatiODS In excess of $75, This is addreued
imposition of pcmaIties on chsrities.                In the Dert lection regardlng Disclosure By
    Legislstion signed into law by !he Presidenl
on Au¡USI ]0, 1993, con18Íns a JJWnbet of                If the goods or services consisl entirely of
aignificant provisions atfccting tax-excmpl          intangible religious beneñts, tbe statemcnl
charitable organizations clescribed in section       should indicate lhis, but tbe statctnent need nol
501 (c)(3) ofthe Intemal Revenllo Code.. These       descn'be or provide an estimate of tbe vaJue
proviiions include: (1) now substantiation           of!bese benofits. "Iatangible religious benefirs"
IeqUirements for donors, md (2) new public           are aIso discussed in tbe folJowing section on
disclosure scquirements for charitios (with          Disclosure By Charity. If, on Ibe o!hor hand, !he
potential penalties for Camng to c:omply).           donor received notbing in retum for !he
AdditionaUy, charities should note lhal donors       contribution, tbe written substantiation must so
couJd be .penalized by los$ of!he deducticn ir       state.
!hey mil to substanliate. THE SUBSTANTIATION
AND DISCLOStIRE PROVlSIONS APPLY TO                    The presenl law remains in effect tila!,
CONTRIBImONS MADE AFI"ER DECEMBER )].              ¡enerally, if!he value of In ilom or group oflilce
1993,                                              items exceeds S5,OOO, tbe donormust obtain a
                                                   qualified apptaisal and submit an appraisaJ
    Charities need to famUisrize !hemselves su1mnaty witil tilc reIUm claiming !he
witb !bese tax law changes in ordcr lo bring deduction.
tbemselves into compliance. This Publication
alerts                                         you     The orgatiizatian may either provide
to tilo new provisions affecting tax<xempl separatc 5tatcments for each contriburlan of
clwitable or¡aDizatiOns. Se! forth below are S250 or more ftom a taxpayor, or fumisb
brief Ibcriptions of!he new law's Icey provisions. periodic staretnents substantiating contributitms
The Intemal Revenue Service plans 10 provide of SZSO or more.
further guidance in !he near fulllnl.
                                                         Separate payments are regarded as
    Donor's Substantiation RelfUirements             independeDt     conlribiltions  and    are   Dot
                                                     aggregated forpurposes ofmcaSuring the S250
    Docamutillll        CerWli       Char:ltabJe     threshold. However, !he Service is authorized 10
Contributioas. - Beginning January 1, 1994, no       establish anti-abuse ruJes lo preven! avoidanc:e
deduction will be aIlowedunder section ]70           of!he subStantiation requirement by taxpayers
ofthe Interna! RevOl1ue Codc for any charitable      writing separatc smallor check! on Ibe same
conttibUtion ofS25O or more unles¡ the doiIor        date.
has colltemporaneous writtcn substantial:ion
from tile Charity. In cases whero the charity has        ]f donations are madc tbrougb payroJl
provided goods or services 10 the donor in -         deductions, !he deduction from eac:b paychcck
exchange for making die conttibution, lhis           is.   regarded     as   a   separate    payment
contemporaneous wriUcn acknowledgement               A charity lbat Icnowingly provides false written
must includc a good faitil estímate ofthe value      substantiatiOD lo a donar may be subjecr to !he
of such goods or sCrvices. Thus, taxpayers may       pena1ties for lidiog and abetting an understate-
DO longer reiy IOlely on a cancelled check 10        menl of tax liability undor section 6701 of!he
substantiate a cash coDtribution of S250 or          Code.
                                                           Disclosure by Charity 01 Receopt 01
    1ñe s~tiation musl be "contemporaneous.                   Quid Pro Quo Contribution
"1ñat is. it musl be 011tained by !he iIonor DO
later tban !he date tbe donor actually files a re-
                                                         Beginniilg January 1, 1994, under new
IUm for!he t8X year in which tbe contribution
                                                     soction 6115 of!he IntemaJ Revc enue Code, a
was madc. ]ftbe retum is flled aftor tbe due        charitabie organization must provide a wnttell
date oT extended due date, Iben Ibe                 disclosure statement to donors who malee a
substantiation must havo becn obtained by !he       payment, described asa "quid pro quo
due dale or extended duo date.                      contribution." in excess ofS75. This requirement
                                                    is separate trom tbe written substantiation
    ne responslbility for obtaining Ibis            required for deductibilily purposos as disc:ussed
sabstantiation Des wlth the donor, wbo must         above. While, in cenain circumstances, ID
request It from tbe eharity. The eharily is not     organization may be &ble 10 meet both
required to record or repon Ibis information 10     requirements wi!h tbe same written document,
tbe IRS on bebalf of donors.                        11I                                       orgllliza
                                                    lion must be careful 10 satisfy !he seclion 611 S
     !be legisls1ion providos !hat substantiation   written disclosure state~ent requiremeDt in a
willl!Q1 be required ir. in accordance wilb         timely manner because ofthe penalties involved.
regulalions prescribed by tbe Sec:retary, tbe       A quid pro quo contribution is a paymcn! made
charily RpCirts directly lo !he IRS tbe             partly          as         a         contribution
informalion required 10 be provided in tbe          and panly for goods or services provided 10 tbe
written substantiation. Al present, tbero are no    donor by tbe charity. Aa example of a quid pro
regulslions establishing proceduros for direct      qua contribution is where the donor givos a char-
reparting by charities 10 tbe IRS of cbaritable     jly $100 in considenuion for a coneen ticket
contributiolts made in 1994. Consequently,          valued al $40. In Ibis example, S60 would be
charilies alld donors should be prcpared lo         deductible. BecallSe !he donor's plyment (quid
providclobtain tbe described substantiation for     pro quo contribution) exceeds 575, !he
1994 contributions of 5250 or more.                 disclosure 5tatement mllSt be furnished, even
                                                    !hough !he deductible amount does not exceed
    There is no presc:ribed format for tbe
written aclalowledgemcót. For cxarnple,
letters. postc:ards or computer-generated                Separate paymentS QfS75 or Jess made at
forma      may       be     acceptable.     Thc     different times of!he year for separate fund-
scknowledgement does not bave 10 include Ibe        !1Iising events will no! be aggregated for
donor's social sccurily or tax idmtificaiion        purposes of tbe S75 threshold. Howevor,lh:
number. 1I mllSl. however. provide sumClenl         Service is authorized 10 develop anti-abuse rules
Information to súbstanliate the amount of!he        toprevent      avoidance     oftbis    dlsclosure
deductible        contri       butlon.      The     reqLÜrement in sitUltions such as Ibe Writing of
aclcnowledgcment should note the Imount of          multiple checks for the &ame tnnsac:tion.
any cash contribUllon However. iflbe donation is
in    tbe     form    ofpropeny.      Ihen  the
acknovo'led¡;emenl mllSl describe. but need not
vllue. such propcny. "&Juauan of tbe donated
property is tbe responsibihty of tbe donor.
    ReqUlred IOoTltten dJsclosure stalemmt             Ibe donor by an organization organized
must:                                             exclusively fOlreligious jl1uposes, and muslbe
(1) mform Ibe donor lbal Ibe amounl of!he         ofa type tha.t ¡enerally is not sold in a
contributlon Iba! IS deductible fer federal       coamiercial traDsaction outside the donative
income tax purposes is limited lO Ibe excess of   contexL An example of an lotangible rcligious
any maney (and Ibe value of any property olbor    beriefit would be admission 10 a religious
!han money) contributed by Ibe donor .over !he    cerernony. Tbe exception also ¡enerallyapplies
value of ¡oods or services provided by tile       te de minimis tangible benefits, such as wine,
charity,                                 and.     provided in connecnon wilb a rcligious
                                                  cei'en1ony. The intangible religious benefit ex-
(2) provide Ibe donor witil a¡ood.failb estímate ception, however. does not apply lo such items
oflbe value oflbe ¡oods or services Ibat Ibe as payments fOl tullÍon fOl educanon leading 10
donor received                                    a recognized degree, or for travcl services, or
                                                  consumer goods.
     TIIe charity mÚSl fumisb .lbe statement
inCOMCCticm wilb eilber Ibe ,solicitatian ol           A penalty is ímposed on charities lbat do not
fheJ'CCCipt oftile quid pro quo coolribUtion. meel the disclosure requiren1ents. F or faüurc
Ifthe disclosure statement is fumisbed io 10 make !he required disclosurc in connection
cooncction wilh a particular solicitatioo. ii is with a quid pro que contribution of more than
not necessary for Ibe organizatioo 10 provide 575, tlierc 1's a penalty of $10 per contribUtion,
anolber statement wheo the associated not 10 exceedSS;OOO per fundraising cvent or
cootribUticm is ac:tUallym:eived.                 mailing. Tbe charity may .avoid the penalty if
                                                  it.can show lhattbe faiJurc wa.s due lo
     Tbe disclosure mustbe in writingaul must be rcuonable cause.
made in a manDer lbat is 'rUSOnably likely 10
come      10   Ibe   attention    oflbe    donor.      Please Dote that the preulliD¡ bulc ruJe
Forex8ll1ple, a disclosure in mutll pñnl wiihio a allowiDg donor dedactioDl omy te the enent tbat
largor documeot migbt not meet tbis the pa)'ment exceeds tile falr market value oí
requiremenL                                       tbe goods 01' lemces neelved ia return stI11
                                                  .ppUes generally to all quid pro quo
     ductible fer federal income tax purposes is contribadoDl. Tbe $15 threshold pertalDl only to
limited lO Ibe excess of any maney (and Ibe ti1e obligatioa te disc10se ud the imposltion oí
value of any property olbor !han money) the 510 per contribatlon penalty, uot the ruhi on
contributed by Ibe donor .over !he value of deductiblUty.ofthe paymeat.
¡oods or services provided by tile charity, and.
(2) provide Ibe donor witil a¡ood.failb estímate
oflbe value oflbe¡oods or services Ibat Ibe donor

     TIIe charity mÚSl fumisb .lbe statement
inCOMCCticm wilb eilber Ibe ,solicitatian ol
fheJ'CCCipt oftile quid pro quo coolribUtion.
Ifthe disclosure statement is fumisbed io
cooncction wilh a particular solicitatioo. ii is
not necessary for Ibe organizatioo 10 provide
anolber statement wheo the associated
cootribUticm is ac:tUallym:eived.

    Tbe disclosure mustbe in writingaul must be
made in a manDer lbat is 'rUSOnably likely 10
come     10   Ibe    attention   oflbe    donor.
Forex8ll1ple, a disclosure in mutll pñnl wiihio a
largor documeot migbt not meet tbis

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