THE ORGANIZATION REQUESTING A GRANT SHOULD FURNISH AN OPINION TO THE EFFECT THAT (1) THE ORGANIZATION HAS BEEN CERTIFIED BY THE IRS AND IS IN FACT ACTING AS AN ORGANIZATION DESCRIBED IN SECTION 501(C)(3) OF THE IRC TO WHICH CONTRIBUTIONS ARE DEDUCTIBLE UNDER SECTION 170(C)(2)(B) OF THE INTERNAL REVENUE CODE, AND FURNISH THE ORGANIZATION'S TAX ID NUMBER: AND (2) THAT THE ORGANIZATION IS EITHER: (A) ONE WHICH COMES WITHIN THE DEFINITION CONTAINED IN PARAGRAPHS (1), (2), OR (3) OF SECTION 509(A) OF THE INTERNAL REVENUE CODE: OR (B) THAT IF THE ORGANIZATION IS A "PRIVATE FOUNDATION" AS DESCRIBED IN SECTION 509(A) THAT IT IS ALSO AN "OPERATING FOUNDATION" AS DEFINED IN SECTION 4942(J)(3) OF THE INTERNAL REVENUE CODE.