Robinwood Pool Inc

“Individuals (or families) who have paid initiation fees, monthly dues and periodic assessments to obtain membership in the community swimming pool.”

“Decisions of board of directors subject to vote of membership”

“Board of directors will review tax returns and make them available to membership for review before filing”

“All documents made available upon written request to the board of directors”

“Client Note 1 - NOTE RE: SALE AND DISTRIBUTION OF LIQUIDATED ASSETS:WHERE A SOCIAL CLUB (ROBINWOOD POOL, INC.), QUALIFIED FOR TAX EXEMPTION UNDER SECTION 501(C)(7) IRC FINDS IT IMPRACTICABLE TO CONDUCT ITS EXEMPT ACTIVITIES (RESOLUTION ADOPTED JUNE 29, 2017) AND, AS A RESULT, SELLS ITS PROPERTY (DATE OF SALE: AUGUST 21, 2017) AND LIQUIDATES (PARTIAL DISTRIBUTION TO MEMBERS MADE ON SEPTEMBER 10, 2017; FINAL DISTRIBUTION IN LIQUIDATION TO OCCUR IN 2018), "SUCH SALE IS INCIDENTAL TO ITS EXEMPT PURPOSES" AND THE CLUB IS STILL TO BE CONSIDERED AS OPERATED EXCLUSIVELY FOR PLEASURE, RECREATION AND SIMILAR PURPOSES UP THROUGH THE DATE OF SALE AND DISTRIBUTION OF THE LIQUIDATED ASSETS TO ITS ACTIVE MEMBERS. REV. RUL. 58-501, 1958-2, CB262.LIQUIDATING DISTRIBUTIONS TO CLUB MEMBERS AFTER SALE OF CLUB ASSETS ARE CONSISTENT WITH EXEMPTION UNDER SECTION 501(C)(7) IRC AND DOES NOT CONSTIUTE "INUREMENT". REV. RUL. 58-501, 1958-2, CB262.THE TAX CONSEQUENCES OF A DISTRIBUTION BY AN EXEMPT SOCIAL CLUB OF CASH OR PROPERTY TO ITS MEMBERS IS UNRELATED TO THE TAX CONSEQUENCES UPON THE MEMBERS; CONSEQUENTLY, SUCH A DISTRIBUTION MAY NOT AFFECT A CLUB'S SECTION 501(C)(7) IRC EXEMPT STATUS AND YET CREATE TAXABLE INCOME TO THE MEMBER UNDER SECTION 301 IRC.”

“See explanation to form 990, page 2, line 1 on schedule o (see also form 990, page 2, line 4(a)).”

“Partial liquidating distribution to members = -$780000”