Variety Club Tent No. 6 Charities, Inc. - Page 4

                                         -4-                                          
                    (2) If the answer to issue (1) is “yes”, then whether             
               the retroactive revocation of the favorable ruling letter              
               was an abuse of discretion.                                            





                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated; the stipulation and            
          the stipulated exhibits are incorporated herein by this                     
          reference.                                                                  
               When the petition was filed in the instant case, petitioner            
          was an Ohio not-for-profit corporation, and its principal office            
          was in Cleveland, Ohio.                                                     
               The Variety Club charities were founded in 1936 to raise               
          money for disabled or handicapped children.  At the time of the             
          trial, there were about 80 Variety Club tents (chapters) in the             
          United States, Australia, France, Israel, Mexico, and                       
          Switzerland.                                                                
               Petitioner was incorporated in Ohio on December 17, 1970.              
          Variety Club of Northern Ohio Tent No. 6 (hereinafter sometimes             
          referred to as the Club) was originally formed in the late 1930’s           
          in northern Ohio to benefit handicapped and disadvantaged                   
          children.  The Club is an Ohio not-for-profit corporation.                  
          Petitioner was organized by the Club for the specific purpose of            
          raising funds from the general public for various activities                




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