2026-01-29T12:36:11-06:00 2025-06-30 383635706 REHMANN ROBSON LLC 555 BRIARWOOD CIRCLE STE 300 ANN ARBOR MI 48108 990 2024-07-01 382352462 DETROIT REGIONAL CHAMBER FOUNDATION INC DETR 3139644000 777 WOODWARD AVE STE 800 DETROIT MI 48226 SANDY BARUAH PRESIDENT 3135960353 2026-01-28 1 1 ADAM P WILLIAMS CPA P00641847 7347612005 2026-01-27 2024 2025-03-06 01:10:19Z SANDY BARUAH 777 WOODWARD AVE STE 800 DETROIT MI 48226 18179877 0 X WWW.DETROITCHAMBER.COM X 1981 MI DETROIT REGIONAL CHAMBER FOUNDATION, INC (THE "FOUNDATION") IS DEDICATED TO GROWING PROGRAMS OR INITIATIVES THAT ARE IMPORTANT TO ENSURING THE DETROIT REGION'S ECONOMY IS ONE OF THE FASTEST GROWING IN THE U.S. 4 0 0 52 0 0 10627852 17148034 1274299 974751 72141 57092 0 0 11974292 18179877 1023963 697148 0 0 5750388 6669758 0 0 269465 6797404 7918777 13571755 15285683 -1597463 2894194 4204793 7928051 524903 1353967 3679890 6574084 X DETROIT REGIONAL CHAMBER FOUNDATION, INC. (THE "FOUNDATION") IS DEDICATED TO GROWING PROGRAMS OR INITIATIVES THAT ARE IMPORTANT TO ENSURING THE DETROIT REGION'S ECONOMY IS ONE OF THE FASTEST GROWING IN THE U.S. 0 0 5300203 365161 THE DETROIT PROMISE IS THE FOUNDATION'S UMBRELLA SCHOLARSHIP FOR ALL INCOMING COLLEGE STUDENTS, INCLUDING FOUR-YEAR UNIVERSITY STUDENTS FORMALLY ENROLLING THROUGH THE DETROIT COMPACT SCHOLARSHIP PROGRAM. THE DETROIT PROMISE IS A FOUNDATION ADMINISTERED PROGRAM FUNDED BY THE DETROIT PROMISE ZONE AUTHORITY ("DPZA"). THE DETROIT PROMISE'S ESSENTIAL RESPONSIBILITY IS TO PROVIDE A LAST-DOLLAR SCHOLARSHIP FOR DETROIT HIGH SCHOOL STUDENTS ENTERING AREA COMMUNITY COLLEGES AND PARTICIPATING FOUR-YEAR UNIVERSITIES. PER STATE OF MICHIGAN STATUTE, THE DPZA IS ALLOCATED A PORTION OF STATE PROPERTY TAXES COLLECTED IN THE CITY OF DETROIT FOR THE EXPRESS PURPOSE OF FUNDING A COLLEGE PROMISE PROGRAM. THE DPZA HAS DESINGATED THE FOUNDATION AS ITS PARTNER TO ADMINISTER THIS PROGRAM AND USES THE TAX CAPTURE REVENUE TO ALLOCATE FUNDING TO THE FOUNDATION TO FUND THE PROGRAM WITHIN THE STATUTE GUIDELINES. 3580912 900 1500 MICHAUTO IS MICHIGAN'S ONLY AUTOMOTIVE AND MOBILITY CLUSTER ASSOCIATION TO PROTECT, RETAIN, AND GROW MICHIGAN'S SIGNATURE INDUSTRY WHILE ALSO ENSURING THE STATE'S LEADERSHIP IN ADVANCING THE DEVELOPMENT AND MANUFACTURING OF NEXT-GENERATION MOBILITY TECHNOLOGY. 2264855 11556 0 THE FOUNDATION LEADS A COMPREHENSIVE EDUCATION AND TALENT PORTFOLIO OF PROGRAM AND POLICY WORK IN THE STATE. WITH THE GOAL TO INCREASE POSTSECONDARY DEGREE ATTAINMENT IN SOUTHEAST MICHIGAN TO 60% BY 2030, THE CHAMBER'S WORK WILL GROW THE TALENT POOL FOR EMPLOYERS. 1524955 319531 973251 ECONOMIC DEVELOPMENT:THE FOUNDATION'S ECONOMIC PROSPERITY STRATEGY POSITIONS THE DETROIT REGION FOR LONG-TERM GLOBAL COMPETITIVENESS FOR THE NEXT DECADE AND BEYOND. THE WORK IS FUNDED THROUGH CONTRIBUTIONS AND GRANTS FROM CORPORATE DONORS AND PRIVATE PHILANTHROPY. THE STRATEGY IS EXECUTED THROUGH A SERIES OF INITIATIVES ENSURING THE REGION IS EDUCATED, EMPLOYED, HEALTHY, AND LEADING IN NEXT-GENERATION MOBILITY.LEADERSHIP DETROIT:LEADERSHIP DETROIT PROVIDES THE FOUNDATION FOR A LIFELONG COMMITMENT TO LEADERSHIP BY CREATING AWARENESS OF KEY ISSUES THAT AFFECT THE DETROIT REGION AND TO CHALLENGE EMERGING AND EXISTING COMMUNITY LEADERS TO BRING ABOUT POSITIVE CHANGE IN THE COMMUNITY THROUGH INFORMED LEADERSHIP.ECONOMIC EQUITY AND INCLUSION:THE FOUNDATION LEVERAGES ITS POSITION AS A COVENER OF BUSINESS TO ENSURE PERVASIVE AND LONG-TERM CHANGE BOTH SOCIETALLY AND ECONOMICALLY. THIS WORK IS ROOTED IN REFLECTIVE FOCUS ON ACCOUNTABILITY INTERNALLY AND EXTERNALLY THROUGH A COMMITMENT TO ENSURING THE REGION'S EQUITABLE FUTURE. 1524955 319531 973251 12670925 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 0 0 0 0 0 1 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 1 136 0 1 0 0 0 0 0 0 0 0 0 0 0 X 4 0 1 0 0 0 1 0 0 1 1 0 0 0 0 0 1 1 1 0 MI X X DETROIT REGIONAL CHAMBER 3139644000 777 WOODWARD AVE SUITE 800 DETROIT MI 48226 SANDY K BARUAH PRESIDENT 15.00 22.50 X X 264301 396451 24210 KAREN BELANS TREASURER 13.00 24.50 X X 135331 251330 11394 MEGAN SPANITZ VICE- PRESIDENT, RESOURCE 11.00 26.50 X X 102906 264612 11832 TAMMY CARNRIKE CHIEF OPERATING OFFICER 4.00 33.50 X X 44374 399372 15450 GLENN STEVENS VICE- PRESIDENT, AUTOMOTIV 37.50 X 285816 0 9307 GREGORY HANDEL VICE PRESIDENT, EDUCATION 37.50 X 226454 0 10881 JASON JURCZYK SENIOR DIRECTOR, ACCOUNTIN 13.00 24.50 X 56159 131037 10127 WENDY NODGE SENIOR DIRECTOR, SIGNATURE 1.00 37.50 X 0 171967 11195 JAMES P CONNARN SENIOR DIRECTOR, MARKETING 1.00 37.50 X 0 180736 5485 DRAKE A HAYNES DIRECTOR, INFORMATION TECH 4.00 33.50 X 13271 119438 8419 BRADLEY WILLIAMS SECRETARY & EXECUTIVE DIRE 17.00 20.50 X 107517 136840 10879 1236129 2051783 129179 6 0 1 0 0 2500000 14648034 17148034 ECONOMIC DEVELOPMENT 900099 508949 508949 LEADERSHIP DETROIT 900099 464302 464302 MICHAUTO 900099 1500 1500 974751 57092 57092 18179877 974751 0 57092 697148 697148 1669722 1317289 313858 38575 3832288 2661050 1043042 128196 319079 224669 79401 15009 451900 318191 112452 21257 396769 311164 75223 10382 2815536 2815536 1164716 1026166 138518 32 547076 248073 298089 914 67319 51994 15325 291194 114424 176770 130939 117395 12708 836 24479 20189 4290 141215 106295 34920 TUITION EXPENSE 2174422 2174422 EVENT PRODUCTION 472312 415149 16427 40736 OTHER 55106 41546 32 13528 SPONSORSHIPS AND DUES 34463 10225 24238 15285683 12670925 2345293 269465 1486872 2043740 1800721 5848846 917200 35465 4204793 7928051 33040 5023 491863 276150 0 1072794 524903 1353967 X 182671 802 3497219 6573282 3679890 6574084 4204793 7928051 2894194 0 X 0 1 X 1 0 X X X 1 DETROIT REGIONAL CHAMBER 380477570 10 1 0 0 1 0 0 1 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 PART IV, SECTION A, LINE 3B: THE FOUNDATION AND THE DETROIT REGIONAL CHAMBER (THE "CHAMBER") HAVE COMMON MANAGEMENT TEAMS. MANAGEMENT HAS A COPY OF THE INTERNAL REVENUE SERVICE DETERMINATION LETTER INDICATING THAT THE CHAMBER QUALIFIES UNDER INTERNAL REVENUE CODE SECTION 501(C)(6). MANAGEMENT ANNUALLY REVIEWS THE CHAMBER'S FINANCIAL ACTIVITY TO ASCERTAIN THAT THE CHAMBER CONTINUES TO SATISFY THE PUBLIC SUPPORT TESTS UNDER INTERNAL REVENUE CODE SECTION 509(A)(2). PART IV, SECTION A, LINE 3C: ANY FUNDS PROVIDED BY THE FOUNDATION TO THE CHAMBER ARE USED BY THE PROGRAMS FOR WHICH THEY ARE INTENDED. ALL PROGRAMS OF BOTH THE FOUNDATION AND THE CHAMBER HAVE THEIR OWN COST CENTERS TO KEEP FINANCIAL ACTIVITY SEGREGATED. THIS ACTIVITY IS MONITORED BY THE ORGANIZATIONS' COMMON MANAGEMENT TEAMS. PART IV, SECTION C, LINE 1: THE MEMBERSHIP OF THE FOUNDATION CONSISTS OF THE MEMBERS OF THE CHAMBER'S EXECUTIVE COMMITTEE. THE CHAMBER'S EXECUTIVE COMMITTEE APPROVES THE SELECTION OF THE FOUNDATION'S BOARD OF DIRECTORS. THE FOUNDATION'S BOARD OF DIRECTORS RECOMMENDS POLICIES THAT ARE SUBMITTED TO THE CHAMBER'S EXECUTIVE COMMITTEE FOR APPROVAL. THE FOUNDATION'S BOARD OF DIRECTORS DOES NOT VOTE ON OR INSTITUTE ANY POLICY INDEPENDENT OF THE CHAMBER. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 DUE TO DETROIT REGIONAL CHAMBER 1072794 1072794 X 18179877 0 18179877 0 18179877 15285683 0 15285683 0 15285683 PART X, LINE 2: THE FOUNDATION'S MANAGEMENT IS NOT AWARE OF ANY UNRECOGNIZED TAX BENEFITS AS OF JUNE 30, 2024 OR 2025. X X X 1 THE REMINGTON GROUP 21820 DOVER CT BEVERLY HILLS MI 48025 ADVISES OF POTENTIAL TARGETS TO MEET WITH AND DOLLAR AMOUNT 0 95300 431055 0 95300 431055 MI 0 JUST FOR KIDS II CHILD CARE LLC 19390 DWYER DETROIT MI 48234 831305782 15000 0 GENERAL SUPPORT HAPPY BOUNCE LLC 58 UNION ECORSE MI 48229 871010098 15000 0 GENERAL SUPPORT ABC MOBILE VISION INC 6115 CASMERE DETROIT MI 48212 474576318 15000 0 GENERAL SUPPORT BEAVERLAND FARMS LLC 15078 BEAVERLAND STREET DETROIT MI 48223 813053686 15000 0 GENERAL SUPPORT BLACK TECH SATURDAYS 2050 15TH STREET DETROIT MI 48216 993796932 501(C)(3) 25000 0 GENERAL SUPPORT DETROIT BALLOON STORE 13238 FENKELL DETROIT MI 48227 990520175 15000 0 GENERAL SUPPORT GIVING AN OUNCE OF PREVENTION INC 2231 INDIANDALE STREET DETROIT MI 48238 264556407 30000 0 GENERAL SUPPORT GUERILLA FOOD LLC DBA PINK FLAMINGO TO GO 5200 CHENE ST DETROIT MI 48211 465027886 15000 0 GENERAL SUPPORT LIVE COAL 840 BLAINE STREET DETROIT MI 48202 880996911 30000 0 GENERAL SUPPORT MAHK-ERE LLC DBA MOCKERY ZERO PROOF 7400 W MCNICHOLS DETROIT MI 48221 364905655 15000 0 GENERAL SUPPORT NEXT CHAPTER BOOKS LLC 16555 E WARREN DETROIT MI 48224 920315499 15000 0 GENERAL SUPPORT SERVICES TO ENHANCE POTENTIAL 2941 S GULLEY ROAD DEARBORN MI 48124 237289763 30000 0 GENERAL SUPPORT THE COLORING MUSEUM LLC 14205 LONGACRE DETROIT MI 48227 991601116 15000 0 GENERAL SUPPORT PART I, LINE 2: GRANT FUNDS ARE RECORDED AND TRACKED USING SEPARATE COST CENTERS IN THE GENERAL LEDGER. THE PROGRAM MANAGER, MONITORS EXPENSES ON A MONTHLY BASIS, WHICH ARE APPROVED BY THE APPROPRIATE EXECUTIVE MANAGEMENT TEAM (EMT) MEMBER. GRANT FUNDS PAID OUT ARE DONE SO THROUGH THE NORMAL ACCOUNTS PAYABLE PROCESS, WITH A CHECK REQUEST OR INVOICE (APPROVED BY PROGRAM MANAGER AND EMT MEMBER) SUBMITTED TO ACCOUNTING. INVOICES ARE ENTERED INTO THE ACCOUNTS PAYABLE SYSTEM, THEN APPROVED BY THE CFO OR SR. DIRECTOR, ACCOUNTING. CHECKS OVER $4,000 REQUIRE TWO SIGNATURES. PROGRESS REPORTS ARE SUBMITTED TO FUNDERS TO SHOW ACTUAL EXPENDITURES COMPARED TO THE APPROVED GRANT BUDGET. X X 1 1 X X X X X X 1 0 0 0 0 0 1 0 0 SANDY K BARUAH PRESIDENT 176021 264031 83480 125220 4800 7200 4140 6210 5544 8316 273985 410977 0 0 KAREN BELANS TREASURER 95940 178174 34855 64732 4536 8424 3623 6728 365 678 139319 258736 0 0 MEGAN SPANITZ VICE- PRESIDENT, RESOURCE 71804 184638 26747 68777 4355 11197 2898 7452 415 1067 106219 273131 0 0 TAMMY CARNRIKE CHIEF OPERATING OFFICER 32943 296491 9876 88884 1555 13997 1035 9315 510 4590 45919 413277 0 0 GLENN STEVENS VICE- PRESIDENT, AUTOMOTIV 222779 0 46237 0 16800 0 9307 0 0 0 295123 0 0 0 GREGORY HANDEL VICE PRESIDENT, EDUCATION 163600 0 53134 0 9720 0 7283 0 3598 0 237335 0 0 0 JASON JURCZYK SENIOR DIRECTOR, ACCOUNTIN 47293 110351 8866 20686 0 0 1809 4222 1229 2867 59197 138126 0 0 WENDY NODGE SENIOR DIRECTOR, SIGNATURE 0 155264 0 16703 0 0 0 6525 0 4670 0 183162 0 0 JAMES P CONNARN SENIOR DIRECTOR, MARKETING 0 149436 0 31300 0 0 0 4838 0 647 0 186221 0 0 DRAKE A HAYNES DIRECTOR, INFORMATION TECH 12102 108921 1169 10517 0 0 432 3891 410 3686 14113 127015 0 0 BRADLEY WILLIAMS SECRETARY & EXECUTIVE DIRE 89146 113458 10979 13974 7392 9408 2985 3799 1802 2293 112304 142932 0 0 PART I, LINE 4A BRADLEY WILLIAMS AND TAMMY CARNRIKE RECEIVED SEVERANCE PAYMENTS FROM DRCF AND RELATED ORGANIZATIONS IN THE AMOUNT OF $4,759 AND $250,520, RESPECTIVELY ON 6/30/25. THE AMOUNTS WILL BE REPORTED ON THE SCHEDULE J FOR THE FYE 6/30/26 IN ACCORDANCE WITH THE CALENDAR YEAR PAYROLL REPORTING. PART I, LINE 6 THE FOUNDATION ACCRUES BONUS COMPENSATION FOR THE CHIEF EXECUTIVE OFFICER AND OTHER EXECUTIVE MANAGEMENT STAFF BASED ON PREDETERMINED PERCENTAGES THAT HAVE BEEN OUTLINED IN THEIR EMPLOYMENT CONTRACTS OR OTHER EMPLOYMENT MEMOS AND APPROVED BY THE COMPENSATION COMMITTEE. THE FINAL BONUS ELIGIBILITY AND AMOUNT IS BASED ON PERFORMANCE EVALUATIONS AND PERCENTAGES OF GOAL ACHIEVEMENT APPROVED BY THE CEO AND THE COMPENSATION COMMITTEE. PAYOUT OF ANY PERFORMANCE BONUS IS SUBJECT TO OVERALL CONSOLIDATED ORGANIZATIONAL FINANCIAL PERFORMANCE TO ENSURE SUFFICIENT FUNDS AND IS NOT PAID UNTIL THE FINANCIAL RESULTS OF THE FOUNDATION'S SUPPORTED ORGANIZATION, THE DETROIT REGIONAL CHAMBER, ARE DETERMINED AT THE END OF THE FISCAL YEAR. THE BONUSES ARE PAID OUT WITHIN 75 DAYS OF THE END OF THE FISCAL YEAR. FOR THE YEAR ENDED JUNE 30, 2025, THE CEO BONUS WAS APPROVED BY THE COMPENSATION COMMITTEE CHAIR TO BE PAID OUT IN JULY 2025. IF THE BOARD APPROVED BUDGETED NET PERFORMANCE RESULTS OF THE CONSOLIDATED CHAMBER WERE NOT MET, THE BONUS AMOUNTS WOULD BE REDUCED OR ELIMINATED SO AS NOT TO CREATE NEGATIVE NET EARNINGS AS COMPARED TO THE BUDGET FOR THE FOUNDATION. BONUS POOLS FOR THE CEO, EXECUTIVE MANAGEMENT TEAM, AND OTHER EMPLOYEES ARE APPROVED BY THE COMPENSATION COMMITTEE. FORM 990, PART VI, SECTION A, LINE 2 THE BOARD OF THE DETROIT REGIONAL CHAMBER FOUNDATION, INC. HAS HISTORICALLY CONSISTED OF PROMINENT BUSINESS LEADERS FROM THE COMMUNITY REPRESENTING A DIVERSITY OF BUSINESS SECTORS. ANY BOARD MEMBERS WHOSE COMPANIES HAVE BUSINESS TRANSACTIONS WITH OTHER BOARD MEMBERS' COMPANIES ENSURE THEY ARE DONE AT "ARMS LENGTH." THE FOUNDATION'S BOARD MEMBERS ARE ALSO IN HIGH DEMAND TO SERVE ON OTHER BOARDS. IT IS NOT UNUSUAL FOR SOME OF THE FOUNDATION'S BOARD MEMBERS TO SIT ON OTHER BOARDS, INCLUDING COMPANIES THAT ARE REPRESENTED ON THE FOUNDATION BOARD. FORM 990, PART VI, SECTION A, LINE 6 THE VOTING MEMBERS OF THE FOUNDATION ARE THOSE PERSONS THAT CONSTITUTE THE EXECUTIVE COMMITTEE OF THE DETROIT REGIONAL CHAMBER'S BOARD OF DIRECTORS. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 IS PREPARED BY AN INDEPENDENT CPA FIRM AND IS REVIEWED BY THE CHIEF EXECUTIVE OFFICER, THE CHIEF OPERATING OFFICER, AND THE CHIEF FINANCIAL OFFICER. THE BOARD OF DIRECTORS HAS APPOINTED AN AUDIT AND FINANCE COMMITTEE, WHICH IS A COMMITTEE OF THE BOARD OF DIRECTORS. THE AUDIT AND FINANCE COMMITTEE'S PRIMARY FUNCTION IS TO ASSIST THE BOARD OF DIRECTORS IN FULFILLING ITS OVERSIGHT RESPONSIBILITIES BY REVIEWING THE FINANCIAL INFORMATION WHICH WILL BE PROVIDED TO THE FOUNDATION AND OTHERS, THE SYSTEM OF INTERNAL CONTROLS WHICH MANAGEMENT AND THE BOARD HAVE ESTABLISHED, AND THE AUDIT PROCESS. IN DOING SO, IT IS THE AUDIT AND FINANCE COMMITTEE'S RESPONSIBILITY TO PROVIDE AN OPEN AVENUE OF COMMUNICATION BETWEEN THE BOARD OF DIRECTORS, MANAGEMENT, AND THE FOUNDATION'S EXTERNAL AUDITORS. PRIOR TO SUBMISSION OF THE FORM 990, THE RETURN IS REVIEWED WITH THE CHAIR OF THE AUDIT AND FINANCE COMMITTEE. FORM 990, PART VI, SECTION B, LINE 15 DETROIT REGIONAL CHAMBER FOUNDATION, INC. SHARES ADMINISTRATIVE STAFF WITH ITS SUPPORTED ORGANIZATION, THE DETROIT REGIONAL CHAMBER. THE CHAMBER AND ITS COMPENSATION COMMITTEE HAVE AN EXTENSIVE PROCESS TO REVIEW ALL MATTERS OF EXECUTIVE COMPENSATION. FORM 990, PART VI, SECTION C, LINE 19 THE FOUNDATION'S GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS ARE NOT AVAILABLE TO THE PUBLIC. DETROIT REGIONAL CHAMBER 777 WOODWARD AVE SUITE 800 DETROIT MI 48226 380477570 SEE PART VII MI 501(C)(6) N/A 0 MICHIGAN FUTURE INC PO BOX 130416 ANN ARBOR MI 48113 383001180 SEE PART VII MI 501(C)(3) LINE 11A, I N/A 0 DETROIT REGIONAL CHAMBER SERVICES INC 777 WOODWARD AVE SUITE 800 DETROIT MI 48226 382479423 AFFINITY SERVICES MI N/A C 0 NATIONAL COMMERCE GROUP 777 WOODWARD AVE SUITE 800 DETROIT MI 48226 203796295 AFFINITY SERVICES MI N/A C 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DETROIT REGIONAL CHAMBER C 2500000 SEE PART VII DETROIT REGIONAL CHAMBER SERVICES INC C 0 SEE PART VII SCHEDULE R, PART II PRIMARY ACTIVITY - THE DETROIT REGIONAL CHAMBER IS A CHAMBER OF COMMERCE AND IS THE SUPPORTED ORGANIZATION OF THE FOUNDATION. MICHIGAN FUTURE, INC'S MISSION IS TO DEVELOP AND ADVANCE A PRACTICAL VISION OF MICHIGAN'S SOCIAL, EDUCATIONAL, AND ECONOMIC FUTURE. SCHEDULE R, PART V SHARED COSTS - THE DETROIT REGIONAL CHAMBER AND DETROIT REGIONAL CHAMBER FOUNDATION, INC. SHARE A COMMON OFFICE AND UTILIZE A COMMON PROFESSIONAL EMPLOYER ORGANIZATION. DIRECT EXPENSES FOR THE FOUNDATION ARE CHARGED DIRECTLY. SHARED FACILITY COSTS, AS WELL AS ADMINISTRATIVE STAFF, ARE ALLOCATED BETWEEN THE ORGANIZATIONS BASED ON FTE. THESE COSTS, AND THE METHOD IN WHICH THEY ARE ALLOCATED ARE DEFINED IN A FORMAL COST SHARING AGREEMENT. THIS COST SHARING AGREEMENT HAS BEEN REVIEWED BY THE TAX DEPARTMENT OF AN INDEPENDENT ACCOUNTING FIRM TO ENSURE THE AGREEMENT AND ALLOCATION METHOD ARE REASONABLE, ARE IN COMPLIANCE WITH THE INTERNAL REVENUE CODE, AND ARE APPLIED IN A CONSISTENT MANNER.