THE TIRBRACKEN GREEN FOUNDATION, INC. ("FOUNDATION") IS ORGANIZED TO SUPPORT BEREA COLLEGE, BEREA, KENTUCKY ("BEREA COLLEGE") AND SHAKERTOWN AT PLEASANT HILL KENTUCKY, INC. ("SHAKERTOWN"), BOTH PUBLIC CHARITIES DESCRIBED IN SECTION 509(A) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED ("CODE").