THE REALTY CORPORATION IS ORGANIZED AS A WHOLLY CONTROLLED TITLE HOLDING CORPORATION AS DESCRIBED IN SECTION 501(C)(2) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED, FOR THE EXCLUSIVE PURPOSE OF HOLDING TITLE TO PROPERTY FOR THE BENEFIT OF THE RHODE ISLAND FREE CLINIC, INC., AN ORGANIZATION EXEMPT FROM FEDERAL INCOME TAX PURSUANT TO SECTION 501(C)(3) OF THE INTERNAL REVEUE CODE OF 1986, AS AMENDED, COLLECTING INCOME THEREFROM AND TURNING OVER THE ENTIRE AMOUNT THEREFORE, LESS THE EXPENSES, THE RHODE ISLAND FREE CLINIC, INC.