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1nt-ernal Revenue Service Department of the Treasury

Date: I n reply refer to:

31 HOPKINS PLAZABALTIMORE, MD 21201Date~ APR 2 7 1990

t>THE BOLLING HAXALL HOUSE FOUNDATIONCIO W BIRCH DOUGLASS IIIMCGUIRE WOODS BATTLE a BOOTHEPO BOX 397RICHMOND, VA 23203

Employer Identification Number:54-1526990

Contact Per'sonlR HUTCHINS

Contact Telephone Nu~ber:(301) 962-9428

Accountin~ Period Endin~:Apr·il 30

Form 990 Required:YES

Addendum Applies:YES

Dear Applicant:

Based on information supplied, and assumin~ vour operations will be asstated in your application for rec09nition of exemption, we haye determinedvou are exempt from Federal income tax under section 5011a) of the InternalRevenue Code as an or9anization described in section 501(c)(31.

We have further determined that VDU are not a private foundation withinthe meanin9 of section 509(a) of the Code, because you are an or9anizationdescribed in section 509(a)(3).

If your sources of support, or your purposes, character, or method ofoperation change, please let us know so we can consider the effect of thechange on your exempt status and foundation status. In the case of an amend-ment to vour or9anizational document or bylaws, please send us a COPy of theamended document or bylaws. Also, vou should inform us of all chang~s in yourname Dr address.

As of Januarv 1, 1984, you are liable for taxes under the FedetalInsurance ContributiQns Act (social security taxes) on remuneration of 5100Dr more vou pay tD each~of vo~r emplovees during a calendar year. You arenot 1iable for the tax imposed under the Fed~ral Unemployment Tax Act IFUTAI.

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Since vou are not a private foundation, you are not subject to the excisetaxes under Chapter 12 of the Code. Howeyer, you are not automatically exemptfrom other Federal excise taxes. If YOU haye an~ questions-~bout excise,emploYment, or othe~ Federal taxes, please let us knQw.

Donors mav deduct contributions to you as provided in sectIon 170 of theCode. Bequests, le9acies, devises, transfers, or 9ifts to you or for vour useare deductible for Federal estate and gift tax purposes if thev meet theapplicable provisions of Code sections 2055, 2106, and 2522.

Contribution deductions are allowable to donors onlv to the extent thattheir contributions are 9ifts, with no consideration received. Ticket pur-chases and similar pavments in conjunction with fundraising events IDav notnecessarily qualifY as deductible contributions! dependin9 on the circum-stances. See Revenue Ruling 67-246, published in Cumulative Bulletin 1967-2,

Letter 947(OO/CG}

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THE BOLLING HAXALL HOUSE FOUNDATION

on page 101, which sets forth guidelines regarding the deductibility, as chari-table contributions, of payments made bv taxpayers for admission to or otherparticipation in fundraising activities for charity.

In the headin9 of this letter we have indicated whether vou must file Form990, Return of Organization Exempt From Income Tax. If Yes is indicated, vouare required to file Form 990 only if your 9r05s receipts each veal' areno r s s l Iv no r e than $25,000t~'Ho\ile-Vel'l if v cu r eee i ve a Fo r a '990 package in themail, please file the return even if YOU do not exceed the 9ross receipts test.If vou are not required to file, simplv attach the label provided, check thebox in the headin9 to indicate that your annual 9ross receipts are normally$25,000 or less, and sign the return.

If a return is required, it must be filed bv the 15th day of the fifthmonth after the end of your annual accountin9 period. A penal tv of S10 a davis Charged when a return is filed late, unless there is reasonable cause fDrthe delay. Howeyer, the maximum p~naltY charged cannot exceed $5,000 or 5 per-cent of your gross receipts for the vear, whichever is less. This penalty mayalso be charged if a return is not complete, so please be sure your return iscomplete before you file it.

YDU are not required to file Federal inco~e tax returns unless YOU aresubject to the tax on unrelated business income under section 511 of the Code.If YOU afe subject to this taxI vou must file an income tax return on Form990-T, Exempt Dr9anization Business Income Tax Return. In this letter we arenot determining whether any of your present or proposed activities are unre-lated trade Dr business as defined in section 513 Df the Code,

You need an employer identification number even if you have no employees.If an employer identification number was not entered on your applicat~onf anumber will be assigned to yOU and YOU will be advised of it. PI~i~e~se thatnumber Dn all returns YOU file and in all cDrrespondence with the InternalReyenue Service.

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If we have indicated in the heading of this letter that an addendumappliesf the enclDsed addendum is an inte9ral part ot this letter.

Because this letter could help resolve any ~ue5t~ons a!out your exemptstatus and foundati~n status, you should keep it in your perm~nent records.

We have sent a COPy of this letter to your representative as indicated inyour power of attorneY.

Letter 947(DO!CG)

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THE BOLLING HAXALL HOUSE FOUNDATION

You are required to make vour annual return available for public inspection forthree vears after the return is due. You are also required to make available aCOPy of your exemption application, and supportin~ documents! and theexemption letter. Failure to make these documents available for publicinspection mav subject you to a penalty of $10 per day for each dav there is afailure to complv (up to a maximum of $5,000 in the case of an annual return),

~"See Internal tfeYl?llue-ScHvi-ce-:-l'/O-iice88-120, 11t88-LCt'-B~ 4!pr,~for~additi"Dnali nf er e a t i o n .

Guidelines under which private foundations IDav relv on this determination, for9ift5? 9rantsf and contributions made after Karch 13, 1989, were liberalizedand published in Rev. Proc. 89-23, Cumulative Bulletin 1989-1, page B14 •

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Letter 947(DO/CG)