2024-08-21T16:13:00-05:00 2023-12-31 621804252 WATKINS UIBERALL PLLC 1661 AARON BRENNER DR STE 300 MEMPHIS TN 38120 990PF 2023-01-01 626040797 TRUST UNDER WILL OF B J WADE C/O FIRST HORIZON BANK WADE 9016812363 4385 POPLAR AVENUE RTC2 MEMPHIS TN 38117 PORTIA ZERILLA VICE PRESIDENT, FIRST HORIZON BANK 9016812363 2024-08-16 1 1 BRYAN D GRISSOM JR P01750233 9017612720 2024-08-16 2023 2024-08-08 14:25:15Z X X 8822706 X X 21195 21195 253000 253000 244877 3314 3314 3314 277509 277509 27300 13650 13650 15180 15180 0 2700 2700 0 7681 7681 0 573 573 0 53434 39784 13650 228731 228731 282165 39784 242381 -4656 237725 294608 289874 289874 228006 228006 452065 118842 118694 105767 90685 90685 90685 7975000 732141 727259 8822706 0 0 X 0 0 0 0 732141 727259 732141 727259 732141 727259 732141 -4656 0 727485 226 727259 CAPITAL GAINS DIVIDENDS P 3314 3314 3314 3314 3304 0 3304 0 3304 0 0 0 0 0 192 3496 0 0 0 0 0 0 0 0 0 0 1 1 TN 1 0 0 0 0 1 N/A FIRST HORIZON BANK 9016812346 4385 POPLAR AVE MEMPHIS TN 38117 0 0 0 0 0 0 0 0 1 2022 0 2022 0 0 0 0 0 0 0 0 0 0 0 0 FIRST HORIZON BANK 4385 POPLAR AVE MEMPHIS TN 38117 TRUSTEE 2.00 27300 0 0 NONE 0 NONE 0 0 700116 0 7975000 8675116 0 0 8675116 130127 8544989 427249 427249 3304 3304 423945 0 423945 0 423945 242381 0 242381 423945 370647 0 0 242381 242381 0 0 0 0 0 0 0 0 0 0 128266 423945 0 0 0 X BAPTIST MEMORIAL HOSPITAL - UNION CITY 1201 BISHOP ST UNION CITY TN 38261 NONE 501(C)(3) HEALTHCARE 114365 DUNLAP ORPHANAGE THE ARP CENTER 918 S PLEASANTBURG DR STE 127 GREENVILLE SC 29607 NONE 501(C)(3) CARE FOR VULNERABLE YOUTH 106749 RIVES UNION CHURCH 888 FENNEL RD UNION CITY TN 38261 NONE 501(C)(3) RELIGION 7617 228731 BAPTIST MEMORIAL HOSPITAL - UNION CITY 1201 BISHOP ST UNION CITY TN 38261 NONE 501(C)(3) HEALTHCARE 117270 DUNLAP ORPHANAGE THE ARP CENTER 918 S PLEASANTBURG DR STE 127 GREENVILLE SC 29607 NONE 501(C)(3) CARE FOR VULNERABLE YOUTH 109459 RIVES UNION CHURCH 888 FENNEL RD UNION CITY TN 38261 NONE 501(C)(3) RELIGION 7810 234539 14 21195 16 244877 14 3314 0 269386 0 269386 0 0 0 0 0 0 0 0 0 0 ACCOUNTING FEES 2700 2700 0 CONT. TO STMT 13 FORM 990-PF STATEMENT REGARDING PART VI-B, LINE 2B THE TESTS FOR QUALIFYING AS A SUPPORTING ORGANIZATION UNDER SECTION 509(A)(3)(B)(III) ARE INHERENTLY SUBJECTIVE. DUE TO THE UNCERTAINTY AS TO WHETHER THE ORGANIZATION COULD SATISFY ALL OF THESE TESTS, IT WAS ULTIMATELY DETERMINED THAT THE ORGANIZATION SHOULD FILE RETURNS AS A PRIVATE FOUNDATION EFFECTIVE JANUARY 1, 2022.THIS DISAGREEMENT AS TO THE PROPER FILING STATUS WAS NOT RESOLVED UNTIL 3/31/2024. ACCORDINGLY, A FORM 1023 WAS SUBMITTED, AND PREPARATION OF THE FORM 990PF WAS STARTED IN 2024 FOR BOTH 2022 AND 2023. UNTIL THE DECISION WAS MADE THAT THE ORGANIZATION SHOULD FILE TAX RETURNS AS A PRIVATE FOUNDATION, NO VALUATION WAS NEEDED FOR ANY TAX FILING PURPOSE.MOREOVER, THE ORGANIZATION MADE SUFFICIENT DISTRIBUTIONS IN 2022 AND 2023 TO SATISFY ALL THE DISTRIBUTION REQUIREMENTS UNDER SECTION 4942 FOR 2022, BUT FOR THE FACT THAT ON THE LAST FORM 1041 FILED BY THE ORGANIZATION FOR 2021, IT ELECTED TO TREAT DISTRIBUTIONS MADE IN THE FIRST 65 DAYS OF 2022 AS IF THOSE DISTRIBUTIONS WERE MADE IN 2021. IF THOSE DISTRIBUTIONS COULD STILL BE COUNTED TOWARDS THE DISTRIBUTION REQUIREMENTS FOR 2022 DESPITE THE 65-DAY ELECTION, THERE WOULD BE NO FAILURE TO FULLY AND TIMELY COMPLY WITH SECTION 4942 FOR 2022. AT THE TIME THE 65 DAY ELECTION WAS MADE FOR THE 2021 TAX YEAR, THE ONLY BENEFICIARIES WERE CHARITABLE ORGANIZATIONS.THE ORGANIZATION THEREFORE DID NOT ACT WILLFULLY AND HAD REASONABLE CAUSE NOT TO VALUE ITS ASSETS FOR PURPOSES OF COMPLIANCE WITH SECTION 4942 PRIOR TO EARLY 2024. SINCE THAT TIME, THE ORGANIZATION HAS DILIGENTLY MOVED FORWARD TO COMPLY WITH ALL OF ITS FILING AND DISTRIBUTION REQUIREMENTS.ACTIONS TAKEN TO COMPLY WITH IRC SECTIONS 4942(A)(2)(B), (C), AND (D) AND THE RELATED REGULATIONS:UPON DISCOVERING THE ISSUE, THE ORGANIZATION MADE A QUALIFYING DISTRIBUTION OF $128,266 ON 3/26/2024 AND IS ELECTING TO TREAT THE DISTRIBUTION AS BEING MADE OUT OF 12/31/2022'S UNDISTRIBUTED INCOME PURSUANT TO IRC 4942(H)(2). FIXED INCOME 118694 105767 EQUITIES 228006 452065 LEGAL FEES 15180 15180 0 BASIS ADJUSTMENT 226 INSURANCE 573 573 0 FOREIGN TAXES 131 131 0 PROPERTY TAXES 7550 7550 0