— in expenses

The specific and sole activities of this corporation are to (i) hold title to property for its tax-exempt parent, gemological institute of america, INC. ("gia"), a nonprofit organization incorporated under the laws of california, exempt from tax under section 501(c)(3) of the internal revenue code of 1986, as amended, (ii) collect the income from such property, and (iii) turn over such income from the property to gia on an annual basis.