THE SOLE ACTIVITY OF THE CHARITY IS THE MAKING OF CHARITABLE CONTRIBUTIONS TO ORGANIZATIONS THAT HAVE BEEN RECOGNIZED BY THE INTERNAL REVENUE SERVICE AS TAX-EXEMPT UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (THE "CODE"), BUT ARE NOT "PRIVATE FOUNDATIONS" WITHIN THE MEANING OF SECTION 509(A) OF THE CODE. IT IS EXPECTED THAT MANY OF THE RECIPIENT CHARITIES WILL BE INVOLVED IN CHARITABLE AC…