Jay and Rose Phillips Family Foundation of Minnesota

The foundation formed the 927 building, LLC to renovate a commercial building located at 927 west broadway in North Minneapolis (the "LLC"). The following are the goals of the LLC that guide the project development:a. Achieving community and economic development that lead to local ownership.b. Purposefully investing in the North Minneapolis community through a catlytic redevelopment of an existing but neglected property.c. Providing employment, resources and creative and community space for the people that live in the North Minneapolis community.d. Bringing new retail to the North Minneapolis community.the LLC is a functionally related business as defined in section 4942 of the Internal Revenue Code for the foundation because the project directly furthers the foundation's mission. Because it is a functionally related business, the foundation's ownership in the LLC is not an excess business holding within the meaning of section 4943 of the Internal Revenue Code.