Advisory opinion letter

Dear Sir:

I am serving as the Director of the Foundation for Later Life Enrichment. We were designated a non-profit, non-private founda tion by the Internal Revenue Service under Section 509(a)(2) of the Internal Revenue Code on January 26, 1977. In addition to funding gerontology research, we were created to provide high quality goods and services to the aged at low cost.

So far, several manufacturers have agreed to donate products to us, and a number have agreed to sell products to us at wholesale prices. However, a question has arisen about the possibility of manufacturers selling goods to us at prices below wholesale and making the difference in price a donation to the Foundation. We are not clear about whether or not this constitutes a violation of the Robinson-Pattman Act, in view of the fact that we are recognized as a non-profit foundation, and may be exempt under Section 5 of the Federal Trade Commission. Regulations.

On Monday, October 31, 1977, I discussed this with David Paul and Alan Rubinstein in your New York office. They recommended I write requesting an Advisory Opinion from your office. Could you please clarify our status in regard to these apparently conflicting regulations? Thanking you in advance for your assistance in this matter, I

remain
Yours truly,
/s/ Stephen Helfand