Zeba Trust

Schedule D, Part X

“This plan is tax exempt. Therefore, no provision for income taxes has been included in the plan's financial statements, and the adoption of FIN 48 and FAS 109 does not apply. A footnote is included on the financial statements to explain this situation: "On June 30, 1972, the Internal Revenue Service issued a determination letter informing the Company that the Plan and the Trust are designed in accordance with applicable sections of the Internal Revenue Code ("IRC"). The Plan has been amended since receiving the determination letter, however, the Plan administrator and tax counsel believe that the Plan is currently designed and being reported in compliance with the applicable requirements of the IRC. Therefore, no provision for income taxes has been included in the Plan's financial statements. U.S. GAAP requires the Plan administrator to evaluate tax positions taken by the Plan and recognize a tax liability (or asset) if the Plan has taken an uncertain position that more likely than not would not be sustained upon examination by the IRS. The Plan administrator has analyzed the tax positions taken by the Plan and has concluded that, as of December 31, 2014, there are no uncertain positions taken, or expected to be taken, that would require recognition of a liability (or asset) or disclosure in the financial statements. The Plan is subject to audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. The Plan administrator believes it is no longer subject to income tax examinations for year prior to 2011."”