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