Jeffrey,
please take a look at the attached excerpt from Form1023 that Davis Polk is
intending to file in connection with the formation of LHW's new private
foundation (which is the entity taking the grant from C.O.U.Q.). Note that
as part of this application copies of the transfer documents are intended to be
attached to the IRS filing and C.O.U.Q. is identified as have more than 25% of
its net assets being transferred to the new entity.
I have sent this to GVD..
Darren K.
Indyke
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New
York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
------------------------------
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| From: | Schwartz, Jeffrey N. <jeffrey.schwartz@dpw.com> | |
| Subject: | The C.O.U.Q. Foundation | |
| Date: | Sat, 22 Dec 2007 02:03:23 GMT | |
| To: | dkiesq@aol.com | |
| Cc: | John W. Zeiger <zeiger@litohio.com>, Verdolini, Mario J. <mario.verdolini@dpw.com> | |
Darren,
I would appreciate it if you could provide me with a copy of The C.O.U.Q
Foundation's IRS determination letter and confirm the accuracy of the
information reflected in the attached as it relates to The C.O.U.Q
Foundation.
Sincerely,
Jeffrey Schwartz
To ensure compliance with requirements imposed by the IRS, we inform you
that, unless explicitly provided otherwise, any U.S. federal tax advice
contained in this communication (including any attachments) is not
intended or written to be used, and cannot be used, for the purpose of
(i) avoiding penalties under the Internal Revenue Code or (ii)
promoting, marketing or recommending to another party any transaction or
matter addressed herein.
Jeffrey N. Schwartz
Davis Polk & Wardwell
450 Lexington Avenue
New York, NY 10017
212-450-4957 (phone)
212-450-3957 (fax)
jeffrey.schwartz@dpw.com
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