PURSUANT TO INTERNAL REVENUE CODE SECTION 4942(H) AND TREASURY REGULATIONS 53.4942(A)-3(D)(2), THE FOUNDATION HEREBY ELECTS TO TREAT CURRENT YEAR QUALIFYING DISTRIBUTIONS IN EXCESS OF THE IMMEDIATELY PRECEDING TAX YEAR'S UNDISTRIBUTED INCOME AS BEING MADE OUT OF UNDISTRIBUTED INCOME FROM THE 2022 TAX YEAR IN THE AMOUNT OF $3,300.