CERTIFICATION REGARDING TAX-EXEMPT STATUS


I, Richard M. Colombik, of Richard M. Colombik & Associates, P.C., Legal Counsel for Partners In Charity, Inc. ("PIC"), do hereby certify, as of the date written above, the following:

  1. PIC is an IRC §501(c)(3) entity, currently in good standing under the Internal Revenue Code and has continuously maintained this status from the date of its inception.
     

  2. PIC's IRC §501(c)(3) status has not been subject to any final revocation action by the Internal Revenue Service ("IRS").
     

  3. It is possible that the IRS might utilize Revenue Ruling 2006-27 (the "Ruling") or other case law and arguments to challenge the tax-exempt status of PIC and other nonprofit down payment assistance organizations that accept seller participation; however, no current or retroactive revocation has been finalized against PIC. The IRS may also, pursuant to the Ruling, require PIC to alter some methods of operation to comply with said ruling.  In the event the IRS revokes PIC's tax-exempt status, PIC will, to the best of knowledge and belief, promptly disclose such revocation publicly.
     

  4. The statements made in this Certification are true and correct to the best of my knowledge, information, and belief as of the date hereof.

IN WITNESS WHEREOF, I have hereunder set my hand as of the day and year first above written.

 


By: Richard M. Colombik, JD, CPA
Richard M. Colombik & Associates, P.C.