Pennies from Heaven Foundation

Part X, Line 2:

“The Community Foundation for Muskegon County, The Paul C. Johnson Foundation and The Pennies From Heaven Foundation are not-for-profit organizations exempt from federal income taxes under Section 501(c)(3) of the Internal Revenue Code and are also exempt from similar state and local taxes. Although the Organizations were granted income tax exemption by the Internal Revenue Service, such exemption does not apply to any net income that is derived from a trade or business and not in furtherance of the purpose for which it was granted exemption. The Organizations analyzed their filing positions in the federal and state jurisdictions where they are required to file income tax returns, as well as all open tax years in these jurisdictions. The Organizations have also elected to retain their existing accounting policies with respect to the treatment of interest and penalties attributable to income taxes, and continue to reflect any charges for such, to the extent they arise, as a component of their management and general expenses. The Organizations have analyzed its income tax positions for the years 2012 through 2016, the years which remain subject to examination by major tax jurisdictions as of December 31, 2016. The Organizations concluded that there are no significant uncertain tax positions requiring recognition in the Organizations' combined financial statements. The Organizations do not expect the total amount of unrecognized tax benefits ("UTB") (e.g. tax deductions, exclusions, or credits claimed or expected to be claimed) to significantly increase in the next 12 months. The Organizations do not have any amounts accrued for interest and penalties related to UTB at December 31, 2016 and 2015, and they are not aware of any claims for such amounts by federal or state income tax authorities.”