Amend16RobertWirengard - Page 6

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               a.   The organization is organized exclusively for                     
                    charitable, religious, educational, and/or                        
                    scientific purposes under section 501(c)(3) of the                
                    Internal Revenue Code.                                            
               b.   No part of the net earnings of the organization                   
                    shall inure to the benefit of, or be distributable                
                    to, its members, trustees, officers or other                      
                    private persons, except that the organization                     
                    shall be authorized and empowered to pay                          
                    reasonable compensation for services rendered and                 
                    to make payments and distributions in furtherance                 
                    of the purposes set forth in the purpose clause                   
                    hereof.  No substantial part of the activities of                 
                    the organization shall be the carrying on of                      
                    propaganda, or otherwise attempting to influence                  
                    legislation, and the organization shall not                       
                    participate in, or intervene in (including the                    
                    publishing or distribution of statements) any                     
                    political campaign on behalf of any candidate for                 
                    public office.  Notwithstanding any other                         
                    provision of this document, the organization shall                
                    not carry on any other activities not permitted to                
                    be carried on (a) by an organization exempt from                  
                    federal income tax under section 501(c)(3) of the                 
                    Internal Revenue Code, or corresponding section of                
                    any future federal tax code, or (b) by an                         
                    organization, contributions to which are                          
                    deductible under section 170(c)(2) of the Internal                
                    Revenue Code, or corresponding section of any                     
                    future federal tax code.                                          
               c.   The organization will not discriminate based on                   
                    gender, race, religion, disability, or ethnic or                  
                    national origin.                                                  
          The Agreement stated that the amendment would be adopted in                 
          accordance with petitioner’s internal rules of operation.  Robert           
          Wirengard alone signed the Agreement; the Agreement was not                 
          signed by all directors as required by Article VI of the                    
          Articles.                                                                   








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