TY 2021 Form 990PF

- TIN:

Form990-PF

Department of the Treasury
Internal Revenue Service

Return of Private Foundation

or Section 4947(a)(1) Trust Treated as Private Foundation

Do not enter social security numbers on this form as it may be made public.
bullet

Go to www.irs.gov/Form990PF for instructions and the latest information.

OMB No. 1545-0047

2021

Open to Public Inspection

For calendar year 2021, or tax year beginning 01-01-2021 , and ending 12-31-2021

Name of foundation
The Copley Fund

Number and street (or P.O. box number if mail is not delivered to street address)PO Box 696
Room/suite

City or town, state or province, country, and ZIP or foreign postal code
Morrisville, VT056610696

A Employer identification number

03-6006013

B Telephone number (see instructions)

(802) 888-2000

C If exemption application is pending, check here bullet

G Check all that apply: Initial returnInitial return of a former public charity
Final returnAmended return
Address change Name change

D 1. Foreign organizations, check here............. bullet

2. Foreign organizations meeting the 85%
test, check here and attach computation ... bullet

E If private foundation status was terminated
under section 507(b)(1)(A), check here ....... bullet

H Check type of organization: Section 501(c)(3) exempt private foundation
Section 4947(a)(1) nonexempt charitable trust Other taxable private foundation

F If the foundation is in a 60-month termination
under section 507(b)(1)(B), check here ....... bullet

I Fair market value of all assets at end
of year (from Part II, col. (c),
line 16) bullet

$5,493,190J Accounting method: Cash Accrual
Other (specify)
(Part I, column (d) must be on cash basis.)

	Analysis of Revenue and Expenses (The total of amounts in columns (b), (c), and (d) may not necessarily equal the amounts in column (a) (see instructions).)	(a) Revenue and expenses per books		(b) Net investment income	(c) Adjusted net income	(d) Disbursements for charitable purposes (cash basis only)


1	Contributions, gifts, grants, etc., received (attach schedule)
2	Check .............
3	Interest on savings and temporary cash investments	1		1
4	Dividends and interest from securities...	221,896		221,896
5a	Gross rents............
b	Net rental income or (loss)
6a	Net gain or (loss) from sale of assets not on line 10		64,580
b	Gross sales price for all assets on line 6a 191,345
7	Capital gain net income (from Part IV, line 2)...			64,580
8	Net short-term capital gain.........				0
9	Income modifications...........
10a	Gross sales less returns and allowances
b	Less: Cost of goods sold....
c	Gross profit or (loss) (attach schedule).....		0
11	Other income (attach schedule).......		5,477
12	Total. Add lines 1 through 11........	291,954		286,477	0
13	Compensation of officers, directors, trustees, etc.
14	Other employee salaries and wages......
15	Pension plans, employee benefits.......
16a	Legal fees (attach schedule).........		1,480	1,480
b	Accounting fees (attach schedule).......		0
c	Other professional fees (attach schedule)....		14,276	14,276
17	Interest...............
18	Taxes (attach schedule) (see instructions)...		4,363	22
19	Depreciation (attach schedule) and depletion...		0
20	Occupancy..............
21	Travel, conferences, and meetings.......
22	Printing and publications..........
23	Other expenses (attach schedule).......		5,841	841
24	Total operating and administrative expenses.
	Add lines 13 through 23..........	25,960		16,619		0
25	Contributions, gifts, grants paid.......	242,313				242,313
26	Total expenses and disbursements. Add lines 24 and 25	268,273		16,619		242,313
27	Subtract line 26 from line 12:
a	Excess of revenue over expenses and disbursements	23,681
b	Net investment income (if negative, enter -0-)			269,858
c	Adjusted net income (if negative, enter -0-)...				0

For Paperwork Reduction Act Notice, see instructions.

Cat. No. 11289X Form 990-PF (2021)

Form 990-PF (2021)

Page 2

Part II		Balance Sheets	Beginning of year	End of year
Part II		Balance Sheets	(a) Book Value	(b) Book Value	(c) Fair Market Value
	1	Cash—non-interest-bearing.............
	2	Savings and temporary cash investments.........	22,391	14,424	14,424
	3	Accounts receivable
		Less: allowance for doubtful accounts
	4	Pledges receivable
		Less: allowance for doubtful accounts
	5	Grants receivable.................
	6	Receivables due from officers, directors, trustees, and other
		disqualified persons (attach schedule) (see instructions).....		0
	7	Other notes and loans receivable (attach schedule)
		Less: allowance for doubtful accounts		0
	8	Inventories for sale or use..............
	9	Prepaid expenses and deferred charges..........
	10a	Investments—U.S. and state government obligations (attach schedule)
	b	Investments—corporate stock (attach schedule).......	453,190	484,530	5,478,766
	c	Investments—corporate bonds (attach schedule).......
	11	Investments—land, buildings, and equipment: basis
		Less: accumulated depreciation (attach schedule)		0
	12	Investments—mortgage loans.............
	13	Investments—other (attach schedule)..........		0
	14	Land, buildings, and equipment: basis
		Less: accumulated depreciation (attach schedule)		0
	15	Other assets (describe )	0	0	0
	16	Total assets (to be completed by all filers—see the
		instructions. Also, see page 1, item I)	475,581	498,954	5,493,190
	17	Accounts payable and accrued expenses..........
	18	Grants payable.................
	19	Deferred revenue.................
	20	Loans from officers, directors, trustees, and other disqualified persons		0
	21	Mortgages and other notes payable (attach schedule)......		0
	22	Other liabilities (describe )	0	0
	23	Total liabilities (add lines 17 through 22).........		0
		Foundations that follow FASB ASC 958, check here
		and complete lines 24, 25, 29 and 30.
	24	Net assets without donor restrictions...........
	25	Net assets with donor restrictions............	475,581	498,954
		Foundations that do not follow FASB ASC 958, check here
		and complete lines 26 through 30.
	26	Capital stock, trust principal, or current funds........
	27	Paid-in or capital surplus, or land, bldg., and equipment fund
	28	Retained earnings, accumulated income, endowment, or other funds
	29	Total net assets or fund balances (see instructions).....	475,581	498,954
	30	Total liabilities and net assets/fund balances (see instructions).	475,581	498,954

Part III

Analysis of Changes in Net Assets or Fund Balances

Total net assets or fund balances at beginning of year—Part II, column (a), line 29 (must agree with end-of-year figure reported on prior year’s return) ...............

475,581

Enter amount from Part I, line 27a .....................

23,681

Other increases not included in line 2 (itemize) bullet

Add lines 1, 2, and 3 ..........................

499,262

Decreases not included in line 2 (itemize) bullet

308

Total net assets or fund balances at end of year (line 4 minus line 5)—Part II, column (b), line 29 .

498,954

Form 990-PF (2021)

Page 3

Part IV

Capital Gains and Losses for Tax on Investment Income

(a) List and describe the kind(s) of property sold (e.g., real estate, 2-story brick warehouse; or common stock, 200 shs. MLC Co.)		(b) How acquired P—Purchase D—Donation	(c) Date acquired (mo., day, yr.)	(d) Date sold (mo., day, yr.)
1 a	Morgan Stanley acct 068081 S/T sales	P	2021-01-01	2021-01-31
b	Morgan Stanley acct 068081 L/T sales	P	2020-01-01	2021-01-31
c	Morgan Stanley acct 067601 S/T sales	P	2021-01-01	2021-01-31
d	Morgan Stanley acct 067601 L/T sales	P	2020-01-01	2021-01-31
e

(e) Gross sales price		(f) Depreciation allowed (or allowable)	(g) Cost or other basis plus expense of sale	(h) Gain or (loss) (e) plus (f) minus (g)
a	17,106	0	15,995	1,111
b	73,999	0	45,164	28,835
c	16,922	0	18,159	-1,237
d	83,317	0	47,446	35,871
e

Complete only for assets showing gain in column (h) and owned by the foundation on 12/31/69				(l) Gains (Col. (h) gain minus col. (k), but not less than -0-) or Losses (from col.(h))
(i) F.M.V. as of 12/31/69		(j) Adjusted basis as of 12/31/69	(k) Excess of col. (i) over col. (j), if any
a	0	0	0	1,111
b	0	0	0	28,835
c	0	0	0	-1,237
d	0	0	0	35,871
e

2	Capital gain net income or (net capital loss)	If gain, also enter in Part I, line 7 If (loss), enter -0- in Part I, line 7	2	64,580
3	Net short-term capital gain or (loss) as defined in sections 1222(5) and (6):
	If gain, also enter in Part I, line 8, column (c) (see instructions). If (loss), enter -0- in Part I, line 8 ...................		3	-126

Form 990-PF (2021)

Page 4

Part V

Excise Tax Based on Investment Income (Section 4940(a), 4940(b), 4940(e), or 4948—see instructions)

1a	Exempt operating foundations described in section 4940(d)(2), check here and enter “N/A" on line 1.
	Date of ruling or determination letter: (attach copy of letter if necessary–see instructions)
b	All other domestic foundations enter 1.39% (0.0139) of line 27b. Exempt foreign organizations enter 4% (0.04) of Part I, line 12, col. (b)
2	Tax under section 511 (domestic section 4947(a)(1) trusts and taxable foundations only. Others enter -0-)	2	0
3	Add lines 1 and 2...........................	3	3,751
4	Subtitle A (income) tax (domestic section 4947(a)(1) trusts and taxable foundations only. Others enter -0-)	4	0
5	Tax based on investment income. Subtract line 4 from line 3. If zero or less, enter -0- .....	5	3,751
6	Credits/Payments:

a	2021 estimated tax payments and 2020 overpayment credited to 2021	6a	3,836
b	Exempt foreign organizations—tax withheld at source......	6b
c	Tax paid with application for extension of time to file (Form 8868)...	6c
d	Backup withholding erroneously withheld ...........	6d

7	Total credits and payments. Add lines 6a through 6d..............		7	3,836
8	Enter any penalty for underpayment of estimated tax. Check here if Form 2220 is attached.		8	0
9	Tax due. If the total of lines 5 and 8 is more than line 7, enter amount owed.......		9
10	Overpayment. If line 7 is more than the total of lines 5 and 8, enter the amount overpaid...		10	85
11	Enter the amount of line 10 to be: Credited to 2022 estimated tax85	Refunded	11

Part VI-A

Statements Regarding Activities

During the tax year, did the foundation attempt to influence any national, state, or local legislation or did

Yes

it participate or intervene in any political campaign? ....................

Did it spend more than $100 during the year (either directly or indirectly) for political purposes? See the instructions

for the definition.................................

If the answer is "Yes" to 1a or 1b, attach a detailed description of the activities and copies of any materials

published or distributed by the foundation in connection with the activities.

Did the foundation file Form 1120-POL for this year?.....................

Enter the amount (if any) of tax on political expenditures (section 4955) imposed during the year:

(1) On the foundation. bullet

$ (2) On foundation managers. bullet

Enter the reimbursement (if any) paid by the foundation during the year for political expenditure tax imposed

on foundation managers. bullet

Has the foundation engaged in any activities that have not previously been reported to the IRS?.......

If "Yes," attach a detailed description of the activities.

Has the foundation made any changes, not previously reported to the IRS, in its governing instrument, articles

of incorporation, or bylaws, or other similar instruments? If "Yes," attach a conformed copy of the changes....

Did the foundation have unrelated business gross income of $1,000 or more during the year?.........

If "Yes," has it filed a tax return on Form 990-T for this year?...................

Was there a liquidation, termination, dissolution, or substantial contraction during the year?.........

If "Yes," attach the statement required by General Instruction T.

Are the requirements of section 508(e) (relating to sections 4941 through 4945) satisfied either:

By language in the governing instrument, or

By state legislation that effectively amends the governing instrument so that no mandatory directions

that conflict with the state law remain in the governing instrument?................

Yes

Did the foundation have at least $5,000 in assets at any time during the year? If "Yes," complete Part II, col. (c),

and Part XIV..................................

Yes

Enter the states to which the foundation reports or with which it is registered (see instructions)

If the answer is "Yes" to line 7, has the foundation furnished a copy of Form 990-PF to the Attorney

General (or designate) of each state as required by General Instruction G? If "No," attach explanation .

Yes

Is the foundation claiming status as a private operating foundation within the meaning of section 4942(j)(3)

or 4942(j)(5) for calendar year 2021 or the taxable year beginning in 2021? See the instructions for Part XIII.

If "Yes," complete Part XIII .............................

Did any persons become substantial contributors during the tax year? If "Yes," attach a schedule listing their names

and addresses. ...............................

Form 990-PF (2021)

Page 5

Part VI-A

Statements Regarding Activities (continued)

At any time during the year, did the foundation, directly or indirectly, own a controlled entity within the

meaning of section 512(b)(13)? If "Yes," attach schedule. See instructions .............

Did the foundation make a distribution to a donor advised fund over which the foundation or a disqualified person had

advisory privileges? If "Yes," attach statement. See instructions.................

Did the foundation comply with the public inspection requirements for its annual returns and exemption application?

Yes

Website address bullet

N/A

The books are in care of bullet

Richard C Sargent Esq Telephone no. bullet

(802) 888-2000

Located at bullet

PO Box 696MorrisvilleVT ZIP+4 bullet

056610696

Section 4947(a)(1) nonexempt charitable trusts filing Form 990-PF in lieu of Form 1041 —check here ......... bullet

and enter the amount of tax-exempt interest received or accrued during the year ........ bullet

16 At any time during calendar year 2021, did the foundation have an interest in or a signature or other authority over YesNo

a bank, securities, or other financial account in a foreign country? .................

16 No

See the instructions for exceptions and filing requirements for FinCEN Form 114. If "Yes", enter the name of the foreign
country bullet

Part VI-B

Statements Regarding Activities for Which Form 4720 May Be Required

File Form 4720 if any item is checked in the "Yes" column, unless an exception applies.

Yes

During the year did the foundation (either directly or indirectly):

(1) Engage in the sale or exchange, or leasing of property with a disqualified person? ...........

1a(1)

(2) Borrow money from, lend money to, or otherwise extend credit to (or accept it from)

a disqualified person? ..............................

1a(2)

(3) Furnish goods, services, or facilities to (or accept them from) a disqualified person? ...........

1a(3)

(4) Pay compensation to, or pay or reimburse the expenses of, a disqualified person? ............

1a(4)

(5) Transfer any income or assets to a disqualified person (or make any of either available

for the benefit or use of a disqualified person)? ......................

1a(5)

(6) Agree to pay money or property to a government official? (Exception. Check "No"

if the foundation agreed to make a grant to or to employ the official for a period

after termination of government service, if terminating within 90 days.) ...............

1a(6)

If any answer is "Yes" to 1a(1)–(6), did any of the acts fail to qualify under the exceptions described in Regulations

section 53.4941(d)-3 or in a current notice regarding disaster assistance? See instructions ..........

Organizations relying on a current notice regarding disaster assistance check here........ bullet

Did the foundation engage in a prior year in any of the acts described in 1a, other than excepted acts,

that were not corrected before the first day of the tax year beginning in 2021? .............

Taxes on failure to distribute income (section 4942) (does not apply for years the foundation was a private

operating foundation defined in section 4942(j)(3) or 4942(j)(5)):

At the end of tax year 2021, did the foundation have any undistributed income (lines 6d

and 6e, Part XII) for tax year(s) beginning before 2021?....................

If "Yes," list the years bullet

20, 20, 20, 20

Are there any years listed in 2a for which the foundation is not applying the provisions of section 4942(a)(2)

(relating to incorrect valuation of assets) to the year’s undistributed income? (If applying section 4942(a)(2)

to all years listed, answer "No" and attach statement—see instructions.) ..............

If the provisions of section 4942(a)(2) are being applied to any of the years listed in 2a, list the years here.

20, 20, 20, 20

Did the foundation hold more than a 2% direct or indirect interest in any business enterprise at

any time during the year? ..............................

If "Yes," did it have excess business holdings in 2021 as a result of (1) any purchase by the foundation

or disqualified persons after May 26, 1969; (2) the lapse of the 5-year period (or longer period approved

by the Commissioner under section 4943(c)(7)) to dispose of holdings acquired by gift or bequest; or (3)

the lapse of the 10-, 15-, or 20-year first phase holding period? (Use Schedule C, Form 4720, to determine

if the foundation had excess business holdings in 2021.) .....................

Did the foundation invest during the year any amount in a manner that would jeopardize its charitable purposes?

Did the foundation make any investment in a prior year (but after December 31, 1969) that could jeopardize its

charitable purpose that had not been removed from jeopardy before the first day of the tax year beginning in 2021? ..

Form 990-PF (2021)

Page 6

Part VI-B

Statements Regarding Activities for Which Form 4720 May Be Required (continued)

During the year did the foundation pay or incur any amount to:

Yes

(1) Carry on propaganda, or otherwise attempt to influence legislation (section 4945(e))? ..........

5a(1)

(2) Influence the outcome of any specific public election (see section 4955); or to carry

on, directly or indirectly, any voter registration drive? ....................

5a(2)

(3) Provide a grant to an individual for travel, study, or other similar purposes? .............

5a(3)

(4) Provide a grant to an organization other than a charitable, etc., organization described

in section 4945(d)(4)(A)? See instructions ........................

5a(4)

(5) Provide for any purpose other than religious, charitable, scientific, literary, or

educational purposes, or for the prevention of cruelty to children or animals? .............

5a(5)

If any answer is "Yes" to 5a(1)–(5), did any of the transactions fail to qualify under the exceptions described in

Regulations section 53.4945 or in a current notice regarding disaster assistance? See instructions ........

Organizations relying on a current notice regarding disaster assistance check here ......... bullet

If the answer is "Yes" to question 5a(4), does the foundation claim exemption from the

tax because it maintained expenditure responsibility for the grant? .................

If "Yes," attach the statement required by Regulations section 53.4945–5(d).

Did the foundation, during the year, receive any funds, directly or indirectly, to pay premiums on

a personal benefit contract? .............................

Did the foundation, during the year, pay premiums, directly or indirectly, on a personal benefit contract? ....

If "Yes" to 6b, file Form 8870.

At any time during the tax year, was the foundation a party to a prohibited tax shelter transaction?

If "Yes", did the foundation receive any proceeds or have any net income attributable to the transaction? .....

Is the foundation subject to the section 4960 tax on payment(s) of more than $1,000,000 in remuneration or

excess parachute payment during the year? .........................

Part VII

Information About Officers, Directors, Trustees, Foundation Managers, Highly Paid Employees,
and Contractors

1 List all officers, directors, trustees, foundation managers and their compensation. See instructions

(a) Name and address	(b) Title, and average hours per week devoted to position	(c) Compensation (If not paid, enter -0-)	(d) Contributions to employee benefit plans and deferred compensation	(e) Expense account, other allowances
Richard C Sargent Esq	Trustee 1.00	0	0	0
PO Box 696 Morrisville,VT05661	Trustee 1.00	0	0	0
Gloria Wing	Trustee 1.00	0	0	0
c/o Sargent Law Office PO Box 696 Morrisville,VT05661	Trustee 1.00	0	0	0

2 Compensation of five highest-paid employees (other than those included on line 1—see instructions). If none, enter “NONE."


(a) Name and address of each employee paid more than $50,000	(b) Title, and average hours per week devoted to position	(c) Compensation	(d) Contributions to employee benefit plans and deferred compensation	(e) Expense account, other allowances
NONE









Total number of other employees paid over $50,000...................				0

Form 990-PF (2021)

Page 7

Part VII

Information About Officers, Directors, Trustees, Foundation Managers, Highly Paid Employees,
and Contractors (continued)

3 Five highest-paid independent contractors for professional services (see instructions). If none, enter "NONE".
(a) Name and address of each person paid more than $50,000	(b) Type of service	(c) Compensation
NONE

Total number of others receiving over $50,000 for professional services............. bullet

Part VIII-A

Summary of Direct Charitable Activities

List the foundation’s four largest direct charitable activities during the tax year. Include relevant statistical information such as the number of organizations and other beneficiaries served, conferences convened, research papers produced, etc.	Expenses
1


2


3


4

Part VIII-B

Summary of Program-Related Investments (see instructions)

Describe the two largest program-related investments made by the foundation during the tax year on lines 1 and 2.	Amount
1


2


All other program-related investments. See instructions.
3

Total. Add lines 1 through 3......................... bullet

Form 990-PF (2021)

Page 8

Part IX

Minimum Investment Return (All domestic foundations must complete this part. Foreign foundations, see instructions.)

Fair market value of assets not used (or held for use) directly in carrying out charitable, etc.,

purposes:

Average monthly fair market value of securities...................

5,665,052

Average of monthly cash balances.......................

108,846

Fair market value of all other assets (see instructions)................

Total (add lines 1a, b, and c).........................

5,773,898

Reduction claimed for blockage or other factors reported on lines 1a and

1c (attach detailed explanation) .............

Acquisition indebtedness applicable to line 1 assets..................

Subtract line 2 from line 1d.........................

5,773,898

Cash deemed held for charitable activities. Enter 1.5% (0.015) of line 3 (for greater amount, see

instructions) .............................

86,608

Net value of noncharitable-use assets. Subtract line 4 from line 3. .......

5,687,290

Minimum investment return. Enter 5% (0.05) of line 5................

284,365

Part X

Distributable Amount (see instructions) (Section 4942(j)(3) and (j)(5) private operating foundations and certain foreign organizations check here right arrow

and do not complete this part.)

Minimum investment return from Part IX, line 6..................

284,365

Tax on investment income for 2021 from Part V, line 5.......

3,751

Income tax for 2021. (This does not include the tax from Part V.) ...

Add lines 2a and 2b............................

3,751

Distributable amount before adjustments. Subtract line 2c from line 1............

280,614

Recoveries of amounts treated as qualifying distributions................

Add lines 3 and 4............................

280,614

Deduction from distributable amount (see instructions).................

Distributable amount as adjusted. Subtract line 6 from line 5. Enter here and on Part XII, line 1 ...

280,614

Part XI

Qualifying Distributions (see instructions)

Amounts paid (including administrative expenses) to accomplish charitable, etc., purposes:

Expenses, contributions, gifts, etc.—total from Part I, column (d), line 26 ..........

Program-related investments—total from Part VIII-B..................

Amounts paid to acquire assets used (or held for use) directly in carrying out charitable, etc.,

purposes...............................

Amounts set aside for specific charitable projects that satisfy the:

Suitability test (prior IRS approval required)....................

Cash distribution test (attach the required schedule) .................

Qualifying distributions. Add lines 1a through 3b. Enter here and on Part XII, line 4.

Form 990-PF (2021)

Page 9

Part XII

Undistributed Income (see instructions)

		(a) Corpus	(b) Years prior to 2020	(c) 2020	(d) 2021
1 Distributable amount for 2021 from Part X, line 7					280,614
2 Undistributed income, if any, as of the end of 2021:
a Enter amount for 2020 only.......				231,724
b Total for prior years:20, 20, 20
3 Excess distributions carryover, if any, to 2021:
a From 2016......	0
b From 2017......	0
c From 2018......	0
d From 2019......
e From 2020......	4,000
f Total of lines 3a through e ........		4,000
4Qualifying distributions for 2021 from Part
XI, line 4: $ 242,313
a Applied to 2020, but not more than line 2a				231,724
b Applied to undistributed income of prior years (Election required—see instructions).....
c Treated as distributions out of corpus (Election required—see instructions)........		0
d Applied to 2021 distributable amount.....					10,589
e Remaining amount distributed out of corpus		0
5 Excess distributions carryover applied to 2021.		4,000			4,000
(If an amount appears in column (d), the same amount must be shown in column (a).)
6Enter the net total of each column as indicated below:
a Corpus. Add lines 3f, 4c, and 4e. Subtract line 5		0
b Prior years’ undistributed income. Subtract line 4b from line 2b ..........			0
c Enter the amount of prior years’ undistributed income for which a notice of deficiency has been issued, or on which the section 4942(a) tax has been previously assessed......
d Subtract line 6c from line 6b. Taxable amount —see instructions ...........			0
e Undistributed income for 2019. Subtract line 4a from line 2a. Taxable amount—see instructions .............				0
f Undistributed income for 2021. Subtract lines 4d and 5 from line 1. This amount must be distributed in 2022 ..........					266,025
7 Amounts treated as distributions out of corpus to satisfy requirements imposed by section 170(b)(1)(F) or 4942(g)(3) (Election may be required - see instructions) .......
8 Excess distributions carryover from 2016 not applied on line 5 or line 7 (see instructions) ...		0
9 Excess distributions carryover to 2022. Subtract lines 7 and 8 from line 6a ......		0
10 Analysis of line 9:
a Excess from 2017....	0
b Excess from 2018....	0
c Excess from 2019....	0
d Excess from 2020....	0
e Excess from 2021....	0

Form 990-PF (2021)

Page 10

Part XIII

Private Operating Foundations (see instructions and Part VI-A, question 9)

1a If the foundation has received a ruling or determination letter that it is a private operating
foundation, and the ruling is effective for 2021, enter the date of the ruling ....... bullet

b Check box to indicate whether the organization is a private operating foundation described in section 4942(j)(3) or4942(j)(5)

2a Enter the lesser of the adjusted net income from Part I or the minimum investment return from Part X for each year listed ..........	Tax year	Prior 3 years			(e) Total
	(a) 2021	(b) 2020	(c) 2019	(d) 2018	(e) Total

b 85% (0.85) of line 2a .........
c Qualifying distributions from Part XI, line 4 for each year listed .....
d Amounts included in line 2c not used directly for active conduct of exempt activities ..........
e Qualifying distributions made directly for active conduct of exempt activities. Subtract line 2d from line 2c ....
3 Complete 3a, b, or c for the alternative test relied upon:
a “Assets" alternative test—enter:
(1) Value of all assets ......
(2) Value of assets qualifying under section 4942(j)(3)(B)(i)
b “Endowment" alternative test— enter 2/3 of minimum investment return shown in Part IX, line 6 for each year listed ..
c “Support" alternative test—enter:
(1) Total support other than gross investment income (interest, dividends, rents, payments on securities loans (section 512(a)(5)), or royalties) ....
(2) Support from general public and 5 or more exempt organizations as provided in section 4942(j)(3)(B)(iii)....
(3) Largest amount of support from an exempt organization
(4) Gross investment income

Part XIV

Supplementary Information (Complete this part only if the foundation had $5,000 or more in
assets at any time during the year—see instructions.)

1Information Regarding Foundation Managers:

aList any managers of the foundation who have contributed more than 2% of the total contributions received by the foundation
before the close of any tax year (but only if they have contributed more than $5,000). (See section 507(d)(2).)

bList any managers of the foundation who own 10% or more of the stock of a corporation (or an equally large portion of the
ownership of a partnership or other entity) of which the foundation has a 10% or greater interest.

2Information Regarding Contribution, Grant, Gift, Loan, Scholarship, etc., Programs:

Check here bullet

if the foundation only makes contributions to preselected charitable organizations and does not accept
unsolicited requests for funds. If the foundation makes gifts, grants, etc. to individuals or organizations under
other conditions, complete items 2a, b, c, and d. See instructions

aThe name, address, and telephone number or e-mail address of the person to whom applications should be addressed:

Richard C Sargent Esq
PO Box 696
Morrisville,VT05661
(802) 888-2000

bThe form in which applications should be submitted and information and materials they should include:

Letter describing project

cAny submission deadlines:

Before the end of the calendar year

dAny restrictions or limitations on awards, such as by geographical areas, charitable fields, kinds of institutions, or other
factors:

Deserving elderly of Lamoille County, Vermont

Form 990-PF (2021)

Page 11

Part XIV

Supplementary Information (continued)

3 Grants and Contributions Paid During the Year or Approved for Future Payment
Recipient	If recipient is an individual, show any relationship to any foundation manager or substantial contributor	Foundation status of recipient	Purpose of grant or contribution	Amount
Name and address (home or business)		Foundation status of recipient	Purpose of grant or contribution	Amount
aPaid during the year
Lamoille Adult Day Health Services 11 Court Street Morrisville,VT05661		publiccharity	Operating supportsenior services	2,500
Lamoille County Civic Association PO Box 844 Morrisville,VT05661		publiccharity	Assist elderly with activities	16,028
River Arts PO Box 829 Morrisville,VT05661		publiccharity	Support of elderlyactivities	5,000
Lamiolle County Meal on Wheels PO Box 1427 Morrisville,VT05661		publiccharity	Assist elderly with food deliveries	5,000
Lamoille Home Health and Hospice 54 Farr Avenue Morrisville,VT05661		publiccharity	Assist elderly with homeservices and hospicecare	15,000
Capstone Community Action Ex Dir 20 Gable Place Barre,VT05641		publiccharity	Assist elderlyLamoille County	15,000
Morristown Centenial Library PO Box 727 Morrisville,VT05661		publiccharity	Provide activities for elderly	3,000
Lanpher Memorial Library PO Box 196 Hyde Park,VT05655		publiccharity	Provide activitiesfor elderly	3,000
Johnson Public Library PO Box 601 Johnson,VT05656		publiccharity	Provide activities for elderly	3,000
Varnum Memorial Library PO Box 198 Jeffersonville,VT05464		publiccharity	Provide activitiesfor elderly	3,000
Glee Merritt Kelley Community Library PO Box 179 Wolcott,VT05680		publiccharity	Provide activities for elderly	3,000
Stowe Free Library PO Box 1029 Stowe,VT05672		publiccharity	Provide activities for elderly	3,000
Lamoille Community Food Share PO Box 173 Morrisville,VT05661		publiccharity	Assist elderlywith food	10,000
Home Share Vermont 105 North Main Street Suite 103 Barre,VT05641		publiccharity	Assist elderlywith housing	500
Central Vermont Council on Aging 109 Professional Drive Morrisville,VT05661		publiccharity	Support senior centeractivities and case management	15,535
134 individuals who wish to remain anonymous Lamoille County,VT05661	None	N/A	Direct assistance to elderly for housing	134,000
Johnson Food Shelf 780 Railroad Street Johnson,VT05656		publiccharity	Food supportfor elderly	3,000
Cambridge Food Shelf 16 Church Street Jeffersonville,VT05464		public charity	Food supportfor elderly	2,750
Total ................................. 3a				242,313

bApproved for future payment

Total ................................. 3b				0

Form 990-PF (2021)

Page 12

Part XV-A

Analysis of Income-Producing Activities

Enter gross amounts unless otherwise indicated.	Unrelated business income		Excluded by section 512, 513, or 514		(e) Related or exempt function income (See instructions.)
1Program service revenue:	(a) Business code	(b) Amount	(c) Exclusion code	(d) Amount	(e) Related or exempt function income (See instructions.)
a
b
c
d
e
f
gFees and contracts from government agencies
2 Membership dues and assessments ....
3 Interest on savings and temporary cash investments ...........			14	1
4 Dividends and interest from securities ....
5 Net rental income or (loss) from real estate:
aDebt-financed property......
bNot debt-financed property.....
6 Net rental income or (loss) from personal property
7 Other investment income .....
8 Gain or (loss) from sales of assets other than inventory ............			18	64,580
9 Net income or (loss) from special events:
10 Gross profit or (loss) from sales of inventory
11 Other revenue: a
b
c
d
e
12 Subtotal. Add columns (b), (d), and (e) ..				286,477

13Total. Add line 12, columns (b), (d), and (e)..................

286,477

(See worksheet in line 13 instructions to verify calculations.)

Part XV-B

Relationship of Activities to the Accomplishment of Exempt Purposes

Line No.	Explain below how each activity for which income is reported in column (e) of Part XV-A contributed importantly to the accomplishment of the foundation’s exempt purposes (other than by providing funds for such purposes). (See instructions.)

Form 990-PF (2021)

Page 13

Part XVI

Information Regarding Transfers To and Transactions and Relationships With Noncharitable Exempt Organizations

Did the organization directly or indirectly engage in any of the following with any other organization described in section 501(c) (other than section 501(c)(3) organizations) or in section 527, relating to political organizations?

Yes

Transfers from the reporting foundation to a noncharitable exempt organization of:

(1) Cash...................................

1a(1)

(2) Other assets.................................

1a(2)

Other transactions:

(1) Sales of assets to a noncharitable exempt organization....................

1b(1)

(2) Purchases of assets from a noncharitable exempt organization..................

1b(2)

(3) Rental of facilities, equipment, or other assets.......................

1b(3)

(4) Reimbursement arrangements...........................

1b(4)

(5) Loans or loan guarantees.............................

1b(5)

(6) Performance of services or membership or fundraising solicitations................

1b(6)

Sharing of facilities, equipment, mailing lists, other assets, or paid employees..............

If the answer to any of the above is "Yes," complete the following schedule. Column (b) should always show the fair market value
of the goods, other assets, or services given by the reporting foundation. If the foundation received less than fair market value
in any transaction or sharing arrangement, show in column (d) the value of the goods, other assets, or services received.

(a) Line No.	(b) Amount involved	(c) Name of noncharitable exempt organization	(d) Description of transfers, transactions, and sharing arrangements

Is the foundation directly or indirectly affiliated with, or related to, one or more tax-exempt organizations
described in section 501(c) (other than section 501(c)(3)) or in section 527? ...........Yes No

If "Yes," complete the following schedule.

(a) Name of organization	(b) Type of organization	(c) Description of relationship

Sign Here

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.
				May the IRS discuss this return with the preparer shown below? See instructions. Yes No
	Signature of officer or trustee	Date	Title

Paid Preparer Use Only	Print/Type preparer's name	Preparer's Signature	Date	Check if self- employed	PTIN
	Firm's name				Firm's EIN
	Firm's address				Phone no.

Form 990-PF (2021)

Additional Data

Software ID:
Software Version:
Part VI Line 7 -Original Return Overpayment:	-3,836

Form 990PF - Special Condition Description:

Special Condition Description

- TIN:

Note: To capture the full content of this document, please select landscape mode (11" x 8.5") when printing.

TY 2021 GainLossSaleOtherAssetsSch

Name:

The Copley Fund

EIN:

03-6006013

Name	Date Acquired	How Acquired	Date Sold	Purchaser Name	Gross Sales Price	Basis	Basis Method	Sales Expenses	Total (net)	Accumulated Depreciation
Morgan Stanley Investment account 067604		Purchased			100,240	65,605			34,635
Morgan Stanely Investment account 068081		Purchased			91,105	61,160			29,945

- TIN:

TY 2021 InvestmentsCorpStockSchedule

Name:

The Copley Fund

EIN:

03-6006013

Name of Stock	End of Year Book Value	End of Year Fair Market Value
Abbott Laboratories 70 sh	5,137	9,852
Accenture PLC 35 sh	3,775	14,509
Adobe Inc 18 sh	670	10,207
Alphabet Inc 8 sh	2,453	23,176
Amazon Inc 9 sh	7,340	30,009
Ansys Inc 25 sh	3,935	10,028
Apple Inc 70 sh	348	12,430
Bank of America Corp 224 sh	9,384	9,966
Caterpillar Inc 50 sh	7,667	10,337
Ciena Corp New 173 sh	9,335	13,316
CME Group Inc 42 sh	8,580	9,595
Costco Wholesale Corp New 24 sh	2,795	13,625
Darden Restaurants 69 sh	10,062	10,394
Dollar General Corp New 41 sh	4,511	9,669
Dover Corp 72 sh	7,919	13,075
Eaton Corp PLC 59 sh	9,998	10,196
Entegris Inc 55 sh	8,234	7,622
First Republic Bank 55 sh	5,470	11,358
Freeport-McMoran 289 sh	8,958	12,060
Home Depot Inc 34 sh	2,663	14,110
IHS Markit Ltd 95 sh	7,829	12,627
Intuit Inc 18 sh	4,378	11,578
Lululemon Athletica Inc 23 sh	6,332	9,003
Meta Platforms Inc 30 sh	5,977	10,091
Microsoft Corp 32 sh	2,690	10,762
NXP Semiconductors NV 53 sh	7,051	12,072
Old Dominion Freight Line 22 sh	7,897	7,884
Paycom Software Inc 20 sh	6,088	8,304
Paypal Hldgs Inc 40 sh	1,569	7,543
Pioneer Natural Resources 68sh	8,233	12,368
Proctor & Gamble 65 sh	7,206	10,633
Repligen CP 32 sh	9,830	8,475
Roper Technologies Inc 22 sh	4,883	10,821
Sherwin Williams Co Ohio 39 sh	9,043	13,734
Stryker Corp 37 sh	4,026	9,895
Synopsis Inc 31 sh	7,560	11,424
Thermo Fisher Scientific 19 sh	2,654	12,678
United Health Gp Inc 26 sh	7,592	13,056
Visa Inc 42 sh	1,911	9,102
Zoetis Inc 56 sh	3,532	13,666
AO Smith Corp 90 sh	4,207	7,727
Alleghany CP Delaware 11 sh	6,131	7,343
Alliant Energy Corp 109 sh	5,712	6,700
Analog Devices Inc 30 sh	847	5,273
Avery Dennison Corporation 26 sh	1,195	5,631
Bank of Hawaii Corp 80 sh	6,487	6,701
Booz Allen Hamilton Hldg CL A 67 sh	2,619	5,681
Boston Scientific Corp 122 sh	1,025	5,183
Broadridge Fin Solu LLC 59 sh	2,142	10,786
Burlington Stores Inc 23 sh	4,545	6,705
BWX Technologies Inc 137 sh	4,025	6,560
Cargurus Inc 252 sh	6,619	8,477
Casey's General Stores Inc 37 sh	4,752	7,302
CBOE Global Markets Inc 58 sh	5,813	7,563
Clorox Co 31 sh	3,647	5,405
Dollar Gen Corp New 33 sh	2,289	7,782
Donaldson Co Inc 66 sh	3,161	3,911
Dorman Products Inc 43 sh	3,141	4,859
Entergy Corp New 59 sh	4,721	6,646
Epam Systems 11 sh	725	7,353
Expedia Group Inc 380sh	5,197	6,867
Expeditors Intl Wash Inc 74 sh	3,901	9,937
First American Finl Corp 107 sh	2,180	8,371
First Republic Bank 52 sh	4,870	10,739
Fluor Corp New 386 sh	7,254	9,561
Gartner Inc 30 sh	4,116	10,030
Globe Life Inc 73 sh	6,180	6,842
GXO Logistics Inc 81 sh	5,837	7,357
Hasbro Inc 61 sh	2,450	6,209
Helen of Troy 17 sh	1,580	4,156
Hershey Company 31 sh	2,848	5,998
Hexcel Corp 133 sh	7,345	6,889
Hubbell Inc 27 sh	2,843	5,623
Hudson Pacific Properties 275 sh	6,904	6,795
IAA Inc 99 sh	3,808	5,011
Insperity Inc 73 sh	5,626	8,622
Liberty Broadband Corp 55 sh	2,779	8,861
Liberty Media C Ser C SiriusXM 134 sh	3,832	6,814
M&T Bank Corp 31 sh	2,607	4,761
Markel Corp Holding Co 7 sh	6,513	8,638
Nuvasive Inc 111 sh	5,775	5,825
Ollies Bargain Outlet Hldg Inc 75 sh	4,122	3,839
Portland General Electric Co 137 sh	6,168	7,250
Royal Gold Inc 51 sh	5,855	5,366
Solaredge Technologies 30 sh	3,958	8,417
SS&C Technologies Hldgs Inc 95 sh	4,548	7,788
Sun Communities Inc 47 sh	1,278	9,869
Ubiquiti Inc 19 sh	1,427	5,827
Ulta Beauty Inc 14 sh	2,889	5,773
Waters Corp 17 sh	3,589	6,334
Watsco Inc 25 sh	4,444	7,822
Willis Towers Watson Pub Ltd 25 sh	5,823	5,937
XCEL Energy Inc 89 sh	3,000	6,025
Zimmer Biomet Holdings Inc 39 sh	2,166	4,955
Union Bankshares Inc 162000 sh	31,500	4,634,820

- TIN:

TY 2021 LegalFeesSchedule

Name:

The Copley Fund

EIN:

03-6006013

Category	Amount	Net Investment Income	Adjusted Net Income	Disbursements for Charitable Purposes
Fitts Olson & Giddings Tax return prep	1,119	1,119
Sargent Law Office Legal representation	361	361

- TIN:

TY 2021 OtherDecreasesSchedule

Name:

The Copley Fund

EIN:

03-6006013

Description	Amount
Basis adjustment	308

- TIN:

TY 2021 OtherExpensesSchedule

Name:

The Copley Fund

EIN:

03-6006013

Description	Revenue and Expenses per Books	Net Investment Income
Replace stale contribution cks	5,000
Commercial Bond	432	432
Supplies	246	246
Postage	163	163

- TIN:

TY 2021 OtherIncomeSchedule2

Name:

The Copley Fund

EIN:

03-6006013

Description	Revenue And Expenses Per Books	Net Investment Income	Adjusted Net Income
Reversal of stale checks	5,000
Non-dividend distributions	410
Settlement	67

- TIN:

TY 2021 OtherProfessionalFeesSchedule

Name:

The Copley Fund

EIN:

03-6006013

Category	Amount	Net Investment Income	Adjusted Net Income	Disbursements for Charitable Purposes
Morgan Stanley Broker	4,551
Morgan Stanley Broker	5,063
Union Bank Management	4,662

- TIN:

TY 2021 TaxesSchedule

Name:

The Copley Fund

EIN:

03-6006013

Category	Amount	Net Investment Income
Foreign Taxes	22	22
2021 estimates	3,836
2020 tax	505