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Internal Revenue Service <br />Director, Exempt Organizations <br />Date: October 18, 2001 <br />XITTITAS COUNTY HISTORICAL SOCIETY INC <br />G J R & W <br />PO BOX 460 <br />ELLENSBURG WA 98926-0460 <br />Dear Sir or Madam: <br />Department of the Treasury <br />P.O. Box 2508 <br />Cincinnati, Ohio 45201 <br />Person to Contact-ID#:31--07326 <br />Agent William C Jarvi <br />Contact Telephone Numbers: <br />877-829--5500 Phone <br />513-263-3756 FAX <br />Federal identification Number: <br />91-6037783 <br />This is in reference to your letter of May 11, 2001, requesting a <br />ruling regarding your qualification for status as an exempt operating <br />foundation as defined in section 4940(d)(2) of the Internal Revenue Code. <br />Our records indicate you were recognized. as exempt from federal <br />income tax under section 501(c)(3) of the Code effective September of 1974. <br />It was determined the organization was not a private foundation within the <br />meaning of Section 509(x) of the Code because it is an organization <br />described in Section 170(b)(1)(A)(vi) and 509(a). You have also been <br />determined to be a private operating foundation within the meaning of <br />section 4942(j)(3) of the Code as of January 1, 1996. <br />The information submitted indicates your governing body is broadly <br />representative of the general public as evidenced by the large number of <br />area residents of various occupations making up the Board. No Board <br />Members are disqualified persons. <br />Section 4940(a) of the Code provides for the imposition on each <br />exempt private foundation of an excise tax equal to 2 percent of the net <br />investment income of such foundation for the taxable -year. <br />Section 4940(d)(1) of the Code provides no tax shall be imposed under <br />section 4940 on any private foundation which is an exempt operating <br />foundation for the taxable year. <br />Section 4940(d) of the Code was enacted pursuant to the Tax Reform <br />Act of 1984, 1984-3 C.B. (Vol. 1)1 (the "Act"). <br />Section 4940(d)(2) of the Code provides the term "exempt operating <br />foundation" means with respect to any taxable year, any private foundation <br />if— <br />a. such foundation is an operating foundation (as defined in <br />section 4942(j)(3); <br />b. such foundation has been publicly supported for at least 10 <br />taxable years; <br />