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tion has a realistic possibility of being sus- Tax Shelter Analysis as required under Comments and Requests for a Public tained on the merits as a defense to the § 1.6011-4T (or as may be otherwise pro- Hearing penalty imposed under section 6662(b)(1). vided in any successor regulations). The taxpayer instead would be required to

Before these proposed regulations are satisfy the adequate disclosure exception unProposed Effective Date

adopted as final regulations, consideration

will be given to any written (a signed origider § 1.6662–3(c)(1), including the disclo

These regulations are proposed to apsure of the reportable transaction under ply to returns filed after December 30, 2002,

nal and eight (8) copies) or electronic com

ments that are submitted timely to the IRS. § 1.6011-4T. with respect to transactions entered into on

The IRS and Treasury Department request The proposed regulations also clarify and or after January 1, 2003, to coincide with

comments on the clarity of the proposed modify the standards for, and limits on, the the temporary regulations relating to dis- regulations and how they can be made use of opinions and advice to satisfy the closure, promulgated under section 6011 and

easier to understand. All comments will be reasonable cause and good faith excep- applicable for transactions entered into on

available for public inspection and copytion under section 6664(c) as a defense to or after January 1, 2003. The IRS, how

ing. A public hearing may be scheduled if the imposition of the accuracy-related pen- ever, cautions taxpayers and tax practitio- requested in writing by any person that alty under section 6662. The proposed regu

ners that it will rigorously apply the existing timely submits written comments. If a publations, for instance, clarify that a taxpayer's facts and circumstances standard under

lic hearing is scheduled, notice of the date, education, sophistication and business ex- § 1.6664–4(c) regarding a taxpayer's rea

time, and place for the public hearing will perience will be relevant in determining sonable reliance in good faith on advice

be published in the Federal Register. whether the taxpayer's reliance on the opin

from a tax professional, as well as the other ion or advice was reasonable and made in

provisions of the regulations under sec- Drafting Information good faith. The IRS currently takes these

tions 6662 and 6664, including § 1.6664facts and circumstances into account in de4(c) relating to special rules for the

The principal authors of these regulasubstantial understatement penalty attribtermining whether a taxpayer has satis

tions are Jamie G. Bernstein and Heather utable to tax shelter items of a corporafied the reasonable cause and good faith

L. Dostaler of the Office of Associate Chief exception under section 6664(c). tion. In addition to the modifications

Counsel (Procedure and Administration), These proposed regulations amend contained in these proposed regulations, and

Administrative Provisions and Judicial Prac§ 1.6664-4(c) to specify when a taxpayer regardless of when a transaction was en

tice Division. cannot rely upon an opinion or advice to

tered into, the IRS, in appropriate circumsatisfy the reasonable cause and good faith

stances, may consider a taxpayer's failure exception. Taxpayers who do not disclose to disclose a reportable transaction or fail- Proposed Amendments to the

Regulations positions based upon a regulation being in

ure to disclose a position that a regulavalid (see § 1.6662–3(c)(2)) cannot use an tion is invalid as a factor in determining

Accordingly, 26 CFR part 1 is proposed opinion or advice concerning the invalidwhether the taxpayer has satisfied the rea

to be amended as follows: ity of the regulation as a basis for satisfy

sonable cause and good faith exception un-
der section 6664(c) to the accuracy-related

ing the reasonable cause and good faith
exception under section 6664(c). Simi- penalty.

Paragraph 1. The authority citation for larly, the proposed regulations prohibit taxSpecial Analyses

part 1 continues to read in part as follows: payers from using an opinion or advice as

Authority: 26 U.S.C. 7805 * * * a basis for satisfying the reasonable cause It has been determined that this notice

Par. 2. Section 1.6662–3 is amended by: and good faith exception under section of proposed rulemaking is not a signifi

1. Revising paragraph (a). 6664(c) with respect to a reportable trans- cant regulatory action as defined in Ex

2. Revising the last sentence of paraaction that the taxpayer did not disclose in ecutive Order 12866. Therefore, a regulatory graph (b)(2). accordance with $ 1.6011-4T. assessment is not required. It has also been

3. Revising the first sentence of paraUnder these proposed regulations, a tax- determined that section 553(b) of the Ad

graph (c)(1). payer, in order to properly disclose a trans- ministrative Procedure Act (5 U.S.C. chap- The revisions read as follows: action, may be required to file with the

ter 5) does not apply to these regulations, taxpayer's return more than one disclo

and because the regulation does not im- $ 1.6662–3 Negligence or disregard of sure form for the same transaction in or

pose a collection of information on small rules or regulations. der to satisfy the requirements in the entities, the Regulatory Flexibility Act (5 regulations under sections 6662 and 6664 U.S.C. chapter 6) does not apply. Pursu

(a) In general. If any portion of an un(as modified by these proposed regula- ant to section 7805(f) of the Internal Rev- derpayment, as defined in section 6664(a) tions), and section 6011. The IRS and Treaenue Code, this notice of proposed

and § 1.6664–2, of any income tax imsury may consider permitting taxpayers to rulemaking will be submitted to the Chief posed under subtitle A of the Internal Revuse a single disclosure document to sat- Counsel for Advocacy of the Small Busi

enue Code that is required to be shown on isfy those regulations, provided that all re- ness Administration for comment on their

a return is attributable to negligence or disquired information is provided by the impact on small businesses.

regard of rules or regulations, there is added taxpayer and provided that the taxpayer files

to the tax an amount equal to 20 percent a copy of the document with the Office of

of such portion. The penalty for disre

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(c) *


* * * * *

(1) * * *

* * * * *

(b) * * *

garding rules or regulations does not ap- The additions read as follows:

have known, that the advisor lacked knowlply, however, if the requirements of para

edge in the relevant aspects of Federal tax graph (c)(1) of this section are satisfied and $ 1.6664–0 Table of contents.

law. the position in question is adequately dis

(i) * * * In addition, the requirements closed as provided in paragraph (c)(2) of

of this paragraph (C)(1) are not satisfied if this section (and, if the position relates to $ 1.6664-4 Reasonable cause and good the taxpayer fails to disclose a fact that it a reportable transaction as defined in faith exception to section 6662 penalties. knows, or reasonably should know, to be $ 1.6011-4T(b), the transaction is disclosed

relevant to the proper tax treatment of an in accordance with $ 1.6011-4T), or to the

item. extent that the reasonable cause and good faith exception to this penalty set forth in

(iii) Reliance on the invalidity of a regu§ 1.6664_4 applies. In addition, if a posi

(iii) Reliance on the invalidity of a regu

lation. A taxpayer may not rely on an opinlation. tion with respect to an item (other than with

ion or advice that a regulation is invalid to respect to a reportable transaction, as de- (2) Opinions or advice relating to re

establish that the taxpayer acted with reafined in § 1.6011-4T(b)) is contrary to a portable transactions.

sonable cause and good faith unless the taxrevenue ruling or notice (other than a no

payer adequately disclosed, in accordance tice of proposed rulemaking) issued by the Par. 4. Section 1.6664_4 is amended by: with § 1.6662–3(c)(2), including the disInternal Revenue Service and published in

1. Revising paragraph (c)(1) introduc- closure of the position that the regulation the Internal Revenue Bulletin (see tory text.

in question is invalid, and, if the position § 601.601(d)(2) of this chapter), this pen- 2. Revising the last sentence of para- relates to a reportable transaction as dealty does not apply if the position has a regraph (c)(1)(i).

fined in § 1.6011-4T(b), the transaction is alistic possibility of being sustained on its

3. Adding paragraph (c)(1)(iii).

disclosed in accordance with $ 1.6011– merits. See § 1.6694–2(b) of the income tax

4. Redesignating paragraphs (c)(2) and 4T. return preparer penalty regulations for a de

(c)(3) as paragraphs (c)(3) and (c)(4), re- (2) Opinions or advice relating to rescription of the realistic possibility stan- spectively.

portable transactions. Taxpayers may not dard.

5. Adding a new paragraph (c)(2).

reasonably rely on an opinion or advice of The revision and additions read as

a tax advisor if the opinion or advice is dis(2) * * * Nevertheless, a taxpayer who follows:

qualified under this paragraph. An opintakes a position (other than with respect to

ion or advice is disqualified if it relates to a reportable transaction, as defined in $ 1.6664-4 Reasonable cause and good

the appropriate tax treatment of a report$ 1.6011-4T(b)) contrary to a revenue rul- faith exception to section 6662 penalties.

able transaction, as defined in § 1.6011ing or a notice has not disregarded the rul

(c) Reliance on opinion or advice (1)

4T(b), and the taxpayer does not disclose ing or notice if the contrary position has a Facts and circumstances; minimum re

the transaction in accordance with § 1.6011realistic possibility of being sustained on its

4T. quirements. All facts and circumstances merits.

must be taken into account in determin

ing whether a taxpayer has reasonably re(c) *** (1) *** No penalty under sec- lied in good faith on advice (including the

David A. Mader, tion 6662(b)(1) may be imposed on any opinion of a professional tax advisor) as to

Assistant Deputy Commissioner portion of an underpayment that is attrib- the treatment of the taxpayer (or any en

of Internal Revenue. utable to a position contrary to a rule or tity, plan, or arrangement) under Federal tax

(Filed by the Office of the Federal Register on December 30, regulation if the position is disclosed in ac- law. For example, the taxpayer's educa

2002, 8:45 a.m., and published in the issue of the Federal Regcordance with the rules of paragraph (c)(2) tion, sophistication and business experi- ister for December 31, 2002, 67 F.R. 79894) of this section (and, if the position relates ence will be relevant in determining whether to a reportable transaction as defined in the taxpayer's reliance on the advice was § 1.6011-4T(b), the transaction is disclosed reasonable and made in good faith. In no Notice of Proposed Rulemakin accordance with $ 1.6011-4T) and, in event will a taxpayer be considered to have ing by Cross-Reference to case of a position contrary to a regula- reasonably relied in good faith on advice Temporary Regulation and tion, the position represents a good faith (including an opinion) unless the require

Notice of Public Hearing challenge to the validity of the regula- ments of this paragraph (c)(1) are satistion.

fied and the advice is not disqualified under Section 6038—Returns Par. 3. Section 1.6664-0 is amended by: paragraph (c)(2) of this section. The fact that Required With Respect to

1. Adding an entry for $ 1.6664- these requirements are satisfied, however, Controlled Foreign 4(c)(1)(iii). will not necessarily establish that the tax

Partnerships 2. Redesignating the entries for payer reasonably relied on the advice (in§ 1.6664-4(c)(2) and (c)(3) as $ 1.6664- cluding the opinion of a professional tax REG-124069-02 4(c)(3) and (c)(4), respectively.

advisor) in good faith. For example, reli3. Adding a new entry for $ 1.6664– ance may not be reasonable or in good faith AGENCY: Internal Revenue Service (IRS), 4(c)(2).

if the taxpayer knew, or reasonably should Treasury.


* * * * *

ACTION: Notice of proposed rulemak- Treasury, Office of Information and Regu

Treasury, Office of Information and Regu- Background and Explanation of ing by cross-reference to temporary regu- latory Affairs, Washington, DC 20503, with Provisions lation and notice of public hearing. copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer,

The temporary regulation in this issue SUMMARY: In this issue of the Bulletin,

of the Bulletin amends 26 CFR part 1. If the IRS is issuing a temporary regulation Comments on the collection of informaW:CAR:MP:FP:S, Washington, DC 20224.

a foreign partnership files Form 1065 or (T.D. 9033) relating to controlled foreign

Form 1065-B and a United States partner tion should be received by February 21, partnerships. That document requires that

is required to file Form 8865 with respect 2003. Comments are specifically requested the United States partner must follow the

to that partnership, the temporary regulafiling requirements that are specified in the concerning:

tion amends Treas. Reg. § 1.6038–3 to proinstructions for Form 8865. The text of that

Whether the proposed collection of in

vide that the United States partner must regulation also serves as the text of this

formation is necessary for the proper perpro

follow the filing requirements that are speciposed regulation. This document also proformance of the functions of the Internal

fied in the instructions for Form 8865. The vides notice of a public hearing on these Revenue Service, including whether the in

text of the temporary regulation also serves proposed regulations.

formation will have practical utility; as the text of this proposed regulation. The The accuracy of the estimated burden as

preamble to the temporary regulation exDATES: Written or electronic comments

sociated with the proposed collection of in- plains the temporary regulation and this promust be received by March 24, 2003. Out- formation (see below);

posed regulation. lines of topics to be discussed at the pub

How the quality, utility, and clarity of the lic hearing scheduled for March 12, 2003,

Special Analyses information to be collected may be enat 10 a.m., must be received by February hanced;

It has been determined that this notice 19, 2003.

How the burden of complying with the of proposed rulemaking is not a signifiADDRESSES: Send submissions to:

proposed collection of information may be cant regulatory action as defined in ExCC:ITA:RU (REG-124069-02), room 5226,

minimized, including through the applica- ecutive Order 12866. Therefore, a regulatory Internal Revenue Service, POB 7604, Ben

tion of automated collection techniques or assessment is not required. It has also been Franklin Station, Washington, DC 20044.

other forms of information technology; and determined that section 553(b) of the AdSubmissions may be hand delivered Mon

Estimates of capital or start-up costs and

ministrative Procedure Act (5 U.S.C. chapday through Friday between the hours of costs of operation, maintenance, and pur- ter 5) does not apply to these regulations 8 a.m. and 5 p.m. to: CC:ITA:RU (REG

chase of service to provide information. and because this regulation does not im124069–02), Courier's Desk, Internal Rev

The collection of information in this pose a collection of information on small enue Service, 1111 Constitution Avenue, regulation is in § 1.6038–31. This infor- entities, a Regulatory Flexibility Analysis NW, Washington, DC. Alternatively, tax

mation is required by the IRS to identify under the Regulatory Flexibility Act (5 payers may submit electronic comments di- foreign partnerships which are controlled by U.S.C. chapter 6) does not apply. Pursurectly to the IRS internet site at United States persons and verify amounts ant to section 7805(f) of the Internal Revregs. The public hearing will be held in the reported by the partners. The collection of enue Code, this notice of proposed Auditorium, Internal Revenue Building,

information is mandatory. The likely re- rulemaking will be submitted to the Chief 1111 Constitution Avenue, NW, Washing- spondents will be individuals and busi- Counsel for Advocacy of the Small Busiton, DC.

ness or other for-profit organizations. ness Administration for comment on its im

The burden of complying with the col- pact on small businesses. FOR FURTHER INFORMATION CON- lection of information required to be re- Comments and Public Hearing TACT: Concerning the proposed regula- ported on Form 8865 is reflected in the tions, Tasheaya Warren, (202) 622–3860; burden for Form 8865. The estimated num- Before this proposed regulation is concerning submissions and the hearing, ber of respondents is 5000. The estimated adopted as a final regulation, considerLaNita Van Dyke, (202) 622–7180 (not toll- burden for the 2001 Form 8865 per re- ation will be given to any written (a signed free numbers). spondent is 89 hours.

original and eight (8) copies) or electronic

An agency may not conduct or spon- comments that are submitted timely to the SUPPLEMENTARY INFORMATION:

sor, and a person is not required to re- IRS. The IRS and Treasury Department rePaperwork Reduction Act

spond to, a collection of information unless quest comments on the clarity of the pro

it displays a valid control number assigned posed rules and how they can be made The collection of information contained by the Office of Management and Bud- easier to understand. All comments will be in this notice of proposed rulemaking has get.

available for public inspection and copybeen submitted to the Office of Manage- Books or records relating to a collec- ing ment and Budget for review in accordance tion of information must be retained as long A public hearing has been scheduled for with the Paperwork Reduction Act of 1995 as their contents may become material in March 12, 2003, at 10 a.m., in the Audi(44 U.S.C. 3507(d)). Comments on the col- the administration of any internal revenue torium, Internal Revenue Building, 1111 lection of information should be sent to the law. Generally, tax returns and tax return Constitution Avenue, NW, Washington, DC. Office of Management and Budget, Attn: information are confidential, as required by Because of access restrictions, visitors will Desk Officer for the Department of the 26 U.S.C. 6103.

not be admitted beyond the immediate en

trance area more than 30 minutes before the (Filed by the Office of the Federal Register on December 20, shareholders”, is corrected to read “loss (or hearing starts. For information about hav2002, 8:45 a.m., and published in the issue of the Federal Reg

gain, as appropriate). The respondents are ister for December 23, 2002, 67 E.R. 78202) ing your name on the building access list

shareholders.” to attend the hearing, see the For Further Information Contact portion of this pre

§ 1.302–5 [Corrected] amble. The rules of 26 CFR 601.601(a)(3) Redemptions Taxable as

2. On page 64339, column 1, § 1.302–5, apply to the hearing. Persons who wish to Dividends; Correction

paragraph (d)(8), line 4 from the bottom of present oral comments must submit writ

the paragraph “accelerated inclusion date ten or electronic comments and an out- Announcement 2003-9

shall be made” is corrected to read “accelline of the topics to be discussed and the

erated loss inclusion date shall be made”. time to be devoted to each topic (a signed AGENCY: Internal Revenue Service (IRS),

3. On page 64340, column 3, § 1.302–5, original and eight (8) copies) by Febru- Treasury.

paragraph (f)(9), of Example 7, lines 6 and ary 19, 2003. A period of 10 minutes will be allotted to each person for making com

ACTION: Correction to notice of proposed 7, the language “equal to PS's basis in the ments. An agenda showing the schedulrulemaking and notice of public hearing. corporation Z stock, ($50 after applica

tion of section 301(c)(2)), is”, is corrected ing of the speakers will be prepared after

SUMMARY: This document contains cor- to read “(equal to PS's basis in the corpothe deadline for receiving outlines has

rections to a notice of proposed rulemak- ration Z stock, ($50 after application of secpassed. Copies of the agenda will be avail

ing and notice of public hearing (REG- tion 301(c)(2)) is”. able free of charge at the hearing.

150313–01, 2002—44 I.R.B. 777) which was

published in the Federal Register on FriDrafting Information

$ 1.304–3 [Corrected] day, October 18, 2002 (67 FR 64331). This

4. On page 64342, column 3, § 1.304–3, The principal author of this regulation regulation provides guidance regarding the

treatment of the basis of redeemed stock is Tasheaya Warren, Office of the Associ

paragraph (a), lines 21 through 24, the lanwhen a distribution in redemption of such ate Chief Counsel (International). How

guage "For the treatment of the redeemed

shareholder's basis in the redeemed stock ever, other personnel from the IRS and stock is treated as a dividend, as well as

in such cases, see § 1.302–5.” is removed. Treasury Department participated in their guidance regarding certain acquisitions of development stock by related corporations that are treated

Cynthia E. Grigsby, as distributions in redemption of stock.


Associate Chief Counsel Proposed Amendments to the Regulations TACT: Lisa K. Leong at (202) 622–7530

(Income Tax and Accounting). (not a toll-free number).

(Filed by the Office of the Federal Register on December 24, Accordingly, 26 CFR part 1 is proposed

2002, 8:45 a.m., and published in the issue of the Federal Regto be amended as follows: SUPPLEMENTARY INFORMATION:

ister for December 26, 2002, 67 F.R. 78761)

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Paragraph 1. The authority citation for The proposed regulations that are the Foundations Status of Certain part 1 continues to read in part as follows:

subject of these corrections are under sec- Organizations Authority: 26 U.S.C. 7805 * * * tions 302, 304, 704, 861, 1371, 1374, and Par. 2. Section 1.6038–3 is amended by

1502 of the Internal Revenue Code. Announcement 2003-10 revising paragraph (j) to read as follows: Need for Correction

The following organizations have failed $ 1.6038–3 Information returns required

to establish or have been unable to mainof certain United States persons with

As published, this notice of proposed

tain their status as public charities or as oprulemaking contains errors that may prove respect to controlled foreign partnerships

erating foundations. Accordingly, grantors to be misleading and are in need of clari(CFPs).

and contributors may not, after this date, fication.

rely on previous rulings or designations in Correction of Publication

the Cumulative List of Organizations (Pub(j) [The text of the proposed amend

lication 78), or on the presumption arisment to § 1.6038–3(j) is the same as the

Accordingly, the publication of the no- ing from the filing of notices under section text for § 1.6038–3T(j) published else

tice of proposed rulemaking and notice of 508(b) of the Code. This listing does not where in this issue of the Federal Regis- public hearing (REG-150303–01, 2002–44 indicate that the organizations have lost their ter.]

I.R.B. 777), which is the subject of FR. status as organizations described in sec-
Doc. 02–26449, is corrected as follows: tion 501(c)(3), eligible to receive deduct-

1. On page 64332, column 1, in the pre- ible contributions.
Robert E. Wenzel, amble under the paragraph heading “Pa- Former Public Charities. The follow-
Deputy Commissioner perwork Reduction Act”, paragraph 7, line ing organizations (which have been treated

of Internal Revenue. 12, the language “loss. The respondents are as organizations that are not private foun

* * * * *

dations described in section 509(a) of the Career Access California, Inc.,
Code) are now classified as private Burlingame, CA

Carolina Family Alliance, Spartanburg, SC

Center for Advanced Transportation
1st Class, Ridgefield, WA

Technologies, Monroeville, PA
360 Whitehall Housing Development

Center for Scientific Visualization, Ltd.,
Fund Corporation, Albany, NY

New York, NY
Abundant Living Self-Investment

Center for Social Ministry, Berkeley, CA
Associates Ministries, Inc.,

Charanjit Singh Batth Foundation,
Little Rock, AR

Caruthers, CA
Access Laporte County, Michigan City, IN

Chennai Educational Foundation, Inc.,
Access to Loans for Learning Finance

Vienna, VA
Corporation, Los Angeles, CA

Cherrie Williams Foundation, Gardena, CA
Access to Loans for Learning Student Credit

Childcare International, Inc., Miami, FL
Corporation, Los Angeles, CA

Children of Peace, Inc., Buffalo, NY
Acrosports Advocate, Detroit, MI

Christian Business & Consumer
Actions Community Development

Ministries Corporation, Fairhope, AL
Corporation, Houston, TX

Christian Family, Greeley, CO
Acts Ministries, Stansbury Park, UT

Circuit Foundation, Brooklyn, NY
ADR Education Foundation, Inc.,

Citizens for Buckeye Basin Parks, Inc.,
Philadelphia, PA

Toledo, OH
African-American Advocacy Education and

Commanchees Retreat Organization,
Training Consultant Group, Incorpo-

Galion, OH
Syracuse, NY

Communities With Vision, Inc.,
African Immigrant Mission USA, Inc.,

Sorrento, FL
West Orange, NJ

Community Development Corporation of
African Universities Foundation, Inc.,

LaFourche, Raceland, LA
Olney, MD

Community Resources Technology, Inc.,
AHEC Foundation of Southwest

Lexington, MA
Oregon, Roseburg, OR

Community Revival Corporation,
Al-Bright Children Educational

Spring Valley, NY
Foundation Trust, San Rafael, CA Communitys Jennie Dean Project,
All Helping Hands, Inc., Lake City, FL Manassas, VA
Allen Temple Neighborhood Development Comprehensive Human Resources, Inc.,

Corporation, Inc., Riviera Beach, FL Newton, MA
American Friends of the Vienna State Connecticut Spirit Association,
Opera, Beverly Hills, CA

Woodbridge, CT
Anchor Bay Square Club,

Copernicus Foundation, Inc., Boston, MA
New Baltimore, MI

Council International Study Programs, Inc.,
Antietam Skating Club, Frederick, MD New York, NY
Artists With Disabilities, Inc., Mahopac, NY Council on Holistic Healing and
Association for Bible Study, New York, NY Recovery, Houston, TX
Astrological Institute, Scottsdale, AZ Covenant Academy, Inc., Asheboro, NC
Bayanihan Cultural Organization,

Crusaders Community Development
Hayward, CA

Corporation, Philadelphia, PA
Berthoud Baseball Association,

David Merrick and Natalie Lloyd
Berthoud, CO

Foundation, Inc., New York, NY
Black Hispanics Educational Foundation, Deep Waters Ministry, Inc.,
Bronx, NY

Port Washington, NY
Bring Me a Book Foundation,

Deliverance Outreach Center,
Mountain View, CA

New Haven, CT
Buffalo Women's Amateur Soccer

D.E.R.E.K. Program, Minneapolis, MN
Association, Ltd., Williamsville, NY District 39 Educational Foundation,
Buttons & Bows Family Child

Wilmette, IL
Development Center, Incorporated, Duplin County Agri-Community Center
Inkster, MI

Foundation, Kenansville, NC
Canon McMillan Baseball Association, Each One Help One Teach One,
Canonsburg, PA

Los Angeles, CA

Eagle Vision Society, Oklahoma City, OK
Easley & Associates Christian Develop-

ment, Inc., West Palm Beach, FL
Eastbridge, Norwalk, CT
Educational Video Foundation,

Silverton, OR
Enable, Inc., Everett, PA
Endangered Liberties Research Institute,

Washington, DC
ESPA, Warrensville Hts., OH
Eufaula-Barbour County Historic

Foundation, Eufaula, AL
F. D. Thomas Educational & Enrichment

Center, Inc., Thomasville, NC
Fire Island Wilderness Committee, Inc.,

Brookhaven, NY
Fire Wind & Rain Ministries,

Council Bluffs, IA
Flame of Fire, Eastman, GA
Foundation for Environmental Education

Development, Reno, NV
Freedom Institute, Springfield, MO
FreshStart, Inc., Memphis, TN
Friendly Village Mobilehome Park

Corporation, Santa Ana, CA
Friends in Friendship, Greensboro, NC
Friends It Is, Sylmar, CA
Full Harvest, Florissant, MO
Fundacion Oftalmologica De La Pena,

Montebello, CA
Fundamental Resources, Inc., Detroit, MI
Garden Square North Development

Company, Pittsburgh, PA
Get High on Life/Be D.E.A.R. to

Yourself, Inc., Huntington Beach, CA
Gethsemane Garden Day Care Center,

Memphis, TN
Global Health Access Foundation,

Tiburon, CA
Global Software Institute, Leverett, MA
Go Ye Ministries, Inc., Alturas, FL
Golden Bridge of Friendship

Organization, Inc., Suffern, NY
Grady County Children & Youth

Coordinating Council, Inc., Cairo, GA
Graham-Kapowsin Community Council,

Spanaway, WA
Green Mountain Wildlife Network,

Middlesex, VT
Haitian American Civic Center, Inc.,

Brooklyn, NY
Hallmark Opportunities for Progressive

Education HOPE, Sebastapol, CA
Hand In Hand We Can, Oakley, CA
Hannah Project, Incorporated, Ocala, FL
Health Beat, Inc., White Plains, NY
Help One Another Club, Inc., Mequon, WI

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