THE ORGANIZATION IS A DELAWARE CHARITABLE TRUST OPERATED EXCLUSIVELY FOR THE BENEFIT OF ITS SUPPORTED ORGANIZATION, NEW YORK BOTANICAL GARDEN, A NEW YORK NOT-FOR-PROFIT CORPORATION RECOGNIZED AS TAX-EXEMPT UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE OF 1986, SECTIONS 509(A) (1) AND 170(B)(1)(A)(VI) OF THE CODE.