THE VIRGINIA ZOOLOGICAL SOCIETY INC (THE "SOCIETY") EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. ORGANIZED ON SEPTEMBER 21, 1979, ITS PURPOSE IS TO ACT AS AN ADVISORY AND SUPPORTIVE ORGANIZATION TO ADVANCE THE DEVELOPMENT OF THE VIRGINIA ZOOLOGICAL PARK (THE "ZOO") IN NORFOLK, VIRGINIA. THE ZOO IS OWNED BY THE CITY OF NORFOLK (THE "CITY"). THE OBJECTIVE OF THE SOCIETY IS TO FOSTER PUBLIC AWARENESS AND APPRECIATION OF THE ZOO AND TO PROMOTE THE CONSERVATION OF THE WORLD'S FLORA AND FAUNA. THE SOCIETY PROVIDES ESSENTIAL PROGRAM SERVICES FOR THE ZOO, AS FOLLOWS: ZOO IMPROVEMENTS AND EXHIBITS: SIGNIFICANT ASSISTANCE FOR ZOO EXPANSION, BUILDING RENOVATIONS AND OTHER VOLUNTEER EFFORTS INTO PROVIDING SERVICES FOR THE ZOO. EDUCATIONAL SERVICES: ENCOURAGES AN UNDERSTANDING OF CONSERVATION TO A WIDE VARIETY OF INDIVIDUALS BY FUNDING AND OPERATING ALL ZOO EDUCATION PROGRAMS (INCLUDING PROGRAMS FOR THE HANDICAPPED AND COMMUNITY OUTREACH PROGRAMS); TRAINING A