Sealed proof · filed Form 990-PF

NAOMI AND NEHEMIAH COHEN FOUNDATION

EIN 20-1135004, tax year January 1, 2024 to December 31, 2024. The return the foundation filed, as the IRS published it, with its arithmetic re-done exactly and sealed September 28, 2026.

Listed in the IRS register as NAOMI AND NEHEMIAH COHEN FOUNDATION VIRGINIA CORPORATION. The name above is as written on the return; the EIN is the same foundation.

This is the latest return the IRS has published for this foundation. Its tax year ended 21 months ago, so a later one may have been filed since and not yet appear in the public file. The IRS received it on October 13, 2025.

The answer

Nothing carried into the next year: the return shows the year’s amount paid within the year.

Every line we re-do agrees with the return as filed.

One field, no account. A person writes to you with the page. Your address goes on our contact list beside this foundation’s name. The page stays either way.

Keep this record for the foundation, year on year: the Filing Record, the foundation’s own order, cancellable in writing for a full refund until thirty days after the filing deadline.

Qualifying distributions1.48×

the distributable amount (Part XI ÷ Part X)

Carried to next year$0

undistributed income, Part XII: nothing carried into the next year

Distributions as a rate7.2%

of net noncharitable-use assets; the legal test is the distributable amount, not this rate

Assets at fair market value$95.6M

end of the tax year, Part II

Largest listed stock13.9%

SIX CIRCLE MGD EQ US UNCON

If that stock halved−6.9%

of total assets, from that one name

Keep This Record

Filing Record: $2,600 a year, direct or at cost through the firm that prepares the return. This page stays whether or not the foundation buys anything. Cancel in writing for any reason, any time up to 30 days after your statutory 990-PF filing deadline (or 12 months from invoice, whichever is earlier): the year is refunded in full to the payer, and seals already generated remain checkable. Or write to a person →

Nothing here can be changed quietly. Try it

NAOMI AND NEHEMIAH COHEN FOUNDATION · Form 990-PF, year ended December 31, 2024checking
Recomputing the seal in your browser…
The foundation’s own public return, sealed through the same free action as yours. Your edits stay in this page: nothing is sent and nothing is saved. A sealed copy shows nothing changed; it does not show the original was correct.

This page’s own short link: paretoalphasystems.com/p/94ea77a87f9e — it fits on a printed page, and whoever opens it can run the same check.

The return’s own arithmetic, re-done

Each line as filed and as recomputed
LineAs filedRecomputedResult
Minimum investment return: 5% of net noncharitable-use assets (Part IX line 6)$4,478,996$4,478,996.45recomputes, within the form's whole-dollar rounding (difference −$0.45)
Excise tax: 1.39% of net investment income (Part V line 1)$145,128$145,127.9679recomputes, within the form's whole-dollar rounding (difference $0.0321)
Distributable amount: minimum investment return − taxes + recoveries − deduction (Part X line 7)$4,333,868$4,333,868recomputes exactly

Where the assets sit, at fair market value

Assets by Part II line, at fair market value
Part II lineFair market valueShare of assets
Savings and temporary cash investments (line 2)$2.4M2.5%
U.S. and state government obligations (line 10a)$5.9M6.2%
Corporate stock (line 10b)$35.7M37.4%
Other investments (line 13)$51.6M54.0%

The ten largest listed stocks, of 25 on the schedule

The schedule ties to Part II line 10b exactly. It behaves like 5.1 equal holdings; the ten largest are 88.3% of the listed stock.

The ten largest listed stocks
Stock, as listedFair market valueShare of assets
SIX CIRCLE MGD EQ US UNCON$13.3M13.9%
FIDELITY 500 INDEX FUND$7M7.3%
SIX CIRCLE MGD EQ US UNCON$4.3M4.5%
APPLE INC$1.9M2.0%
JP MORGAN BETA BUILDERS JAPAN$1.2M1.2%
FINANCIAL SELECT SECTOR SPDR$1M1.1%
JPMORGAN CHASE & CO$958,8401.0%
JP MORGAN BETA BUILDERS CANADA$730,8890.8%
APPLIED MATERIALS INC$650,5200.7%
MCDONALD'S CORP$579,7800.6%

Largest other investments (line 13), as listed

Largest other investments, line 13
JPM 100% US TREASURY$11.3M11.8%
COATUE OFFSHORE FUND, LTD. CLASS A SUB CLASS D TRANCHE 4 - LEAD SERIES$7.3M7.6%
BW PRIVATE INVESTORS OFFSHORE, LTD. CLASS A - LEAD SERIES 01-18$4.4M4.6%
ISRAEL LEGACY PARTNERS$4.3M4.5%
VIRTUS CONVERTIBLE FUND$2.8M2.9%

What the foundation answered on the form

  • Part VI-B 4a: did the foundation invest during the year in a manner that would jeopardize its charitable purposes? No
  • Part VI-B 4b: did it make any investment in a prior year that could jeopardize its charitable purpose and that had not been removed from jeopardy? No
  • Part VI-B 3a: did it hold more than a 2% direct or indirect interest in any business enterprise? Yes
  • Part VI-B 3b: did it have excess business holdings? No
  • Part VI-B 2a: did it have undistributed income for prior years? No

Quoted as filed. These are the foundation’s own answers; this page does not test them.

Control statement · nine controls

Nine controls, read from the return.

Each control reads one part of the filed return and states a fact in a fixed vocabulary: agrees, differs, reported, not reported, not applicable, not checked. Whether any of it met a requirement is counsel’s question, not this page’s.

Recomputed each time the page is read; not part of the seal. The seal covers the body above (controls v2, kernel@2026-09-15.1).

This return: 4 agree, 4 reported, 1 not checked.

ControlReadsResultDetail
Minimum investment returnPart IX line 6 against 5% of line 5, prorated for a short yearagreesFiled $4,478,996; recomputed $4,478,996.45; agrees within the form's whole-dollar rounding.
Excise taxPart V line 1 against 1.39% of net investment incomeagreesFiled $145,128; recomputed $145,127.96; agrees within the form's whole-dollar rounding.
Distributable amountPart X line 7 against the form's own chain from line 1agreesFiled $4,333,868; recomputed $4,333,868; agrees to the dollar.
Payout coveragePart XI total against Part X line 7reportedQualifying distributions $6,417,011 against a distributable amount of $4,333,868 (1.48×).
Payout deadlinePart XII undistributed income and the date it falls duereportedPart XII reports $0 undistributed income for the year ended 31 December 2024: nothing carried into the next year, so nothing from this year falls due by 31 December 2025.
Holdings tie-outThe corporate-stock schedule against Part II line 10bagrees25 listed holdings sum to Part II line 10b exactly; the largest is 13.9% of total assets.
The foundation's own answersPart VI-B 2a, 3a, 3b, 4a and 4b, each answeredreportedAll 5 answered; Yes to Part VI-B 3a.
Filing timelinessThe e-file timestamp beside the original due date and the extension window, each with its IRC §7503 roll to the next business dayreportedReturn timestamped 13 October 2025; the original due date was 15 May 2025; the six-month extension window ended 15 November 2025 (a Saturday, so 17 November 2025 under IRC §7503). Whether an extension was granted is not visible in the e-file; the timestamp is the preparer software's, not the IRS receipt.
Year-to-year continuityThis year's opening balances against last year's closingnot checkedNeeds the prior year's return; one sealed year cannot check itself.

A line that differs is the return’s figure beside the recomputed one, as filed and as recomputed. The return may carry a reason this page cannot read: a schedule filed on paper, an election, a later amendment. It is not a finding. The page is not indexed. It is read by whoever holds the link: the person who asked for it, and anyone the foundation sends it to, its preparer first.

Year-to-year continuity needs two filed years on record. The years, below, reads this foundation’s filed returns in order and holds each against the one before.

The calendar ahead

A payout is owed on last year’s assets, whatever this year’s market does.

Recomputed each time the page is read; not part of the seal. The seal covers the body above (forward v2, kernel@2026-09-15.1). Read against October 8, 2026.

ByWhatAmountBasis
May 15, 2026
Passed
Excise tax on the year ending 31 December 2025, due with that return by 15 May 2026. That date has passed; the figure for that year is on its own return, not this one.$145,127Projected under the assumptions below
December 31, 2026Distributable amount for the year ending 31 December 2025, to be paid out$4,333,868Projected under the assumptions below

If net noncharitable-use assets fell 20% over the year ending December 31, 2025: what is owed now, nothing from Part XII, is unchanged; the following year’s minimum investment return would be $3,583,197, $895,799 less than the projection.

The assumptions, the forward kernel proof, and what was refused
  • Net noncharitable-use assets for the year ending 31 December 2025 equal this return's Part IX line 5, $89579929; the thirteen-month average is not observable from a filing.
  • Net investment income for that year equals this return's, $10440861.
  • No recoveries, income tax or deduction next year; the rates stay 5% and 1.39%; a full tax year.
  • The fall shown is 20% of net noncharitable-use assets, applied to next year's average only; what is already owed was computed on this year's average and is unchanged.
  • Forward kernel proof (the projection’s own, recomputed, not sealed) 0b39cd8ecb6589ea… · kernel@2026-09-15.1 · forward v2, controls v2
  • A projection under the stated assumptions, from the foundation's own filed figures; not a forecast, not advice.
  • The foundation's preparer computes the actual amounts from the year's monthly values; this page states what the last return implies if nothing changes.
  • What is already owed was computed on last year's average assets and does not change with this year's market.

Walk through it with a person →

The years · carryover chain

One return is one year. The payout is kept across six.

What a foundation leaves undistributed is due by the end of the next tax year, and what it distributes beyond the year’s amount may be applied in the five years after. So what is owed, and what may be set against it, is only readable across the filed years. The IRS publishes those years; this reads them in order, re-adds each Part XII, and holds each year’s opening lines against the year before’s closing lines.

Sealed under a hash of their own the first time they are opened; not part of the seal above.

Up to six filed returns, read from the IRS and sealed under one hash, at a page of their own. Nothing about you is recorded.

The seal

Recomputed just now: it matches what was sealed on September 28, 2026. Anyone can check it without us.

For your auditor: what this hash is over, and how to check it from the IRS’s own file
proof 94ea77a87f9e13446d37f00b4d22b884d67e9bcd4f78127a6f50169b3ca03538 · recomputed now, matches
return Form 990-PF, IRS object 202542869349100234, schema 2024v5.2 — the file as the IRS published it hashes to 618766fa7712b4a1…
source file 202542869349100234_public.xml inside 2025_TEOS_XML_11B.zip at irs.gov — not part of the seal; fetch it yourself with verify_proof.py 94ea77a87f9e --fetch
arithmetic kernel@2026-09-15.1 · kernel proof 8111ac213cbc5d7b…
rules b839212b6742304a91af2ff9e04e24acdb32ac9fd48760e6b89289b532c4c45b · commit 7dd856f88a5e — the digest of the 990-PF rules this proof was sealed under (body v2); a proof of the same return under later rules names this hash as superseded

This page is not listed on this site and asks search engines not to index it. It is reached by its link, which whoever asked for it holds.

This foundation’s finance lead or counsel: to add a note beside this page, ask for a correction, or keep the record, write to us.

11,842 foundation returns re-done by the same code; in 11,827 every line we recompute agrees. The study.

This page stays whether or not the foundation buys anything.

Filing Record: $2,600 a year, direct or carried at cost by the firm that prepares the return.

Check It at /verifyKeep This Record
The program, and the full body that was hashed
let total_assets_fmv = 95599343 USD
let mix_savings = share(2359529 USD, total_assets_fmv)
let mix_government = share(5883583 USD, total_assets_fmv)
let mix_stock = share(35742895 USD, total_assets_fmv)
let mix_other = share(51608216 USD, total_assets_fmv)
let net_noncharitable_assets = 89579929 USD
let mir_filed = 4478996 USD
let mir_recomputed = net_noncharitable_assets * 5%
let mir_difference = mir_filed - mir_recomputed
let net_investment_income = 10440861 USD
let excise_filed = 145128 USD
let excise_recomputed = net_investment_income * 1.39%
let excise_difference = excise_filed - excise_recomputed
let distributable_filed = 4333868 USD
let distributable_recomputed = 4478996 USD - 145128 USD + 0 USD - 0 USD
let distributable_difference = distributable_filed - distributable_recomputed
let qualifying_distributions = 6417011 USD
let payout_coverage = qualifying_distributions / distributable_filed
let payout_rate = share(qualifying_distributions, net_noncharitable_assets)
let undistributed_to_next_year = 0 USD
let stocks = [13264152 USD, 6989045 USD, 4262512 USD, 1912985 USD, 1159496 USD, 1036872 USD, 958840 USD, 730889 USD, 650520 USD, 579780 USD, 439530 USD, 438780 USD, 431148 USD, 430064 USD, 410592 USD, 378150 USD, 329745 USD, 289570 USD, 248700 USD, 190400 USD, 145350 USD, 141905 USD, 120640 USD, 114730 USD, 88500 USD]
let stock_count = count(stocks)
let largest_stock = max(stocks)
let largest_stock_share_of_assets = share(largest_stock, total_assets_fmv)
let top10_share_of_stock = share(sum([13264152 USD, 6989045 USD, 4262512 USD, 1912985 USD, 1159496 USD, 1036872 USD, 958840 USD, 730889 USD, 650520 USD, 579780 USD]), sum(stocks))
let stock_concentration = hhi(stocks)
let effective_stock_holdings = 1 / stock_concentration
let largest_stock_halved_share_of_assets = share(largest_stock * 50%, total_assets_fmv)
{
  "mix": [
    {
      "fmv": "2359529",
      "line": "savings",
      "label": "Savings and temporary cash investments (line 2)",
      "share": "0.0246814353107008277243076869263"
    },
    {
      "fmv": "5883583",
      "line": "government",
      "label": "U.S. and state government obligations (line 10a)",
      "share": "0.0615441781854086591369147798432"
    },
    {
      "fmv": "35742895",
      "line": "stock",
      "label": "Corporate stock (line 10b)",
      "share": "0.373882224274281884970694829984"
    },
    {
      "fmv": "51608216",
      "line": "other",
      "label": "Other investments (line 13)",
      "share": "0.539838605376189666910158577136"
    }
  ],
  "kind": "public-filing-990pf",
  "lens": "AXIOM",
  "build": {
    "commit": "7dd856f88a5ecf553ea48f52397c50a503af0e0d",
    "digest": "b839212b6742304a91af2ff9e04e24acdb32ac9fd48760e6b89289b532c4c45b"
  },
  "filer": {
    "ein": "201135004",
    "name": "NAOMI AND NEHEMIAH COHEN FOUNDATION"
  },
  "scope": [
    "Every figure here is the foundation's own filed return or exact arithmetic on it; nothing is estimated.",
    "A 990-PF is a year-end snapshot. Prudence is judged at the time of each decision, which a filing cannot show.",
    "This page neither establishes nor rules out any tax consequence, and no return is prepared or amended here.",
    "A line that differs is the return's figure beside the recomputed one, as filed and as recomputed. The return may carry a reason this page cannot read: a schedule filed on paper, an election, a later amendment. It is not a finding."
  ],
  "checks": [
    {
      "id": "minimum_investment_return",
      "note": null,
      "filed": "4478996",
      "label": "Minimum investment return: 5% of net noncharitable-use assets (Part IX line 6)",
      "verdict": "rounding",
      "difference": "-0.45",
      "recomputed": "4478996.45"
    },
    {
      "id": "excise_tax",
      "note": null,
      "filed": "145128",
      "label": "Excise tax: 1.39% of net investment income (Part V line 1)",
      "verdict": "rounding",
      "difference": "0.0321",
      "recomputed": "145127.9679"
    },
    {
      "id": "distributable_amount",
      "note": null,
      "filed": "4333868",
      "label": "Distributable amount: minimum investment return − taxes + recoveries − deduction (Part X line 7)",
      "verdict": "exact",
      "difference": "0",
      "recomputed": "4333868"
    }
  ],
  "engine": "kernel@2026-09-15.1",
  "source": {
    "form": "990-PF",
    "lines": {
      "netInvestmentIncome": "10440861",
      "grossInvestmentIncome": "11091362",
      "netNoncharitableAssets": "89579929",
      "undistributedCurrentYear": "0"
    },
    "period": {
      "end": "2024-12-31",
      "days": 366,
      "begin": "2024-01-01"
    },
    "amended": false,
    "foreign": {
      "organization": false,
      "meets85PctTest": false
    },
    "objectId": "202542869349100234",
    "returnTs": "2025-10-13T16:39:10-05:00",
    "operating": false,
    "sourceSha256": "618766fa7712b4a106e7c67e340a6294b0565915760bf5c6c36e04dc5d9dff17",
    "returnVersion": "2024v5.2",
    "partXBoxChecked": false
  },
  "answers": [
    {
      "answer": "No",
      "question": "Part VI-B 4a: did the foundation invest during the year in a manner that would jeopardize its charitable purposes?"
    },
    {
      "answer": "No",
      "question": "Part VI-B 4b: did it make any investment in a prior year that could jeopardize its charitable purpose and that had not been removed from jeopardy?"
    },
    {
      "answer": "Yes",
      "question": "Part VI-B 3a: did it hold more than a 2% direct or indirect interest in any business enterprise?"
    },
    {
      "answer": "No",
      "question": "Part VI-B 3b: did it have excess business holdings?"
    },
    {
      "answer": "No",
      "question": "Part VI-B 2a: did it have undistributed income for prior years?"
    }
  ],
  "program": "let total_assets_fmv = 95599343 USD\nlet mix_savings = share(2359529 USD, total_assets_fmv)\nlet mix_government = share(5883583 USD, total_assets_fmv)\nlet mix_stock = share(35742895 USD, total_assets_fmv)\nlet mix_other = share(51608216 USD, total_assets_fmv)\nlet net_noncharitable_assets = 89579929 USD\nlet mir_filed = 4478996 USD\nlet mir_recomputed = net_noncharitable_assets * 5%\nlet mir_difference = mir_filed - mir_recomputed\nlet net_investment_income = 10440861 USD\nlet excise_filed = 145128 USD\nlet excise_recomputed = net_investment_income * 1.39%\nlet excise_difference = excise_filed - excise_recomputed\nlet distributable_filed = 4333868 USD\nlet distributable_recomputed = 4478996 USD - 145128 USD + 0 USD - 0 USD\nlet distributable_difference = distributable_filed - distributable_recomputed\nlet qualifying_distributions = 6417011 USD\nlet payout_coverage = qualifying_distributions / distributable_filed\nlet payout_rate = share(qualifying_distributions, net_noncharitable_assets)\nlet undistributed_to_next_year = 0 USD\nlet stocks = [13264152 USD, 6989045 USD, 4262512 USD, 1912985 USD, 1159496 USD, 1036872 USD, 958840 USD, 730889 USD, 650520 USD, 579780 USD, 439530 USD, 438780 USD, 431148 USD, 430064 USD, 410592 USD, 378150 USD, 329745 USD, 289570 USD, 248700 USD, 190400 USD, 145350 USD, 141905 USD, 120640 USD, 114730 USD, 88500 USD]\nlet stock_count = count(stocks)\nlet largest_stock = max(stocks)\nlet largest_stock_share_of_assets = share(largest_stock, total_assets_fmv)\nlet top10_share_of_stock = share(sum([13264152 USD, 6989045 USD, 4262512 USD, 1912985 USD, 1159496 USD, 1036872 USD, 958840 USD, 730889 USD, 650520 USD, 579780 USD]), sum(stocks))\nlet stock_concentration = hhi(stocks)\nlet effective_stock_holdings = 1 / stock_concentration\nlet largest_stock_halved_share_of_assets = share(largest_stock * 50%, total_assets_fmv)",
  "results": {
    "mir_filed": "4478996 USD",
    "mix_other": "0.539838605376189666910158577136",
    "mix_stock": "0.373882224274281884970694829984",
    "mix_savings": "0.0246814353107008277243076869263",
    "payout_rate": "0.0716344729409196115795090661436",
    "stock_count": "25",
    "excise_filed": "145128 USD",
    "largest_stock": "13264152 USD",
    "mir_difference": "-0.45 USD",
    "mir_recomputed": "4478996.45 USD",
    "mix_government": "0.0615441781854086591369147798432",
    "payout_coverage": "1.48066600090265785667676080582",
    "total_assets_fmv": "95599343 USD",
    "excise_difference": "0.0321 USD",
    "excise_recomputed": "145127.9679 USD",
    "distributable_filed": "4333868 USD",
    "stock_concentration": "0.197784954858546473438857255376",
    "top10_share_of_stock": "0.882555568036668546294305483649",
    "net_investment_income": "10440861 USD",
    "distributable_difference": "0 USD",
    "distributable_recomputed": "4333868 USD",
    "effective_stock_holdings": "5.05599630019982312073916403656",
    "net_noncharitable_assets": "89579929 USD",
    "qualifying_distributions": "6417011 USD",
    "undistributed_to_next_year": "0 USD",
    "largest_stock_share_of_assets": "0.138747313357582384222033827157",
    "largest_stock_halved_share_of_assets": "0.0693736566787911921110169135786"
  },
  "version": 2,
  "holdings": {
    "tie": "exact",
    "top": [
      {
        "fmv": "13264152",
        "name": "SIX CIRCLE MGD EQ US UNCON",
        "shareOfAssets": "0.138747313357582384222033827157"
      },
      {
        "fmv": "6989045",
        "name": "FIDELITY 500 INDEX FUND",
        "shareOfAssets": "0.0731076676960007978297507755885"
      },
      {
        "fmv": "4262512",
        "name": "SIX CIRCLE MGD EQ US UNCON",
        "shareOfAssets": "0.0445872520274537869993520771372"
      },
      {
        "fmv": "1912985",
        "name": "APPLE INC",
        "shareOfAssets": "0.020010440866732734763668825632"
      },
      {
        "fmv": "1159496",
        "name": "JP MORGAN BETA BUILDERS JAPAN",
        "shareOfAssets": "0.0121287025999749809996079157155"
      },
      {
        "fmv": "1036872",
        "name": "FINANCIAL SELECT SECTOR SPDR",
        "shareOfAssets": "0.0108460159605908588723250953723"
      },
      {
        "fmv": "958840",
        "name": "JPMORGAN CHASE & CO",
        "shareOfAssets": "0.0100297760414525024507752108715"
      },
      {
        "fmv": "730889",
        "name": "JP MORGAN BETA BUILDERS CANADA",
        "shareOfAssets": "0.00764533496846312008650519700747"
      },
      {
        "fmv": "650520",
        "name": "APPLIED MATERIALS INC",
        "shareOfAssets": "0.00680464927462942920015674166296"
      },
      {
        "fmv": "579780",
        "name": "MCDONALD'S CORP",
        "shareOfAssets": "0.00606468603032135900766598364593"
      }
    ],
    "count": 25,
    "schedule": "Corporate stock (line 10b)"
  },
  "refusals": [],
  "blankLines": [],
  "kernelProof": "8111ac213cbc5d7bb02369dbf6e13a2008caf65893ad61c11b9bc575ccfde887",
  "otherInvestments": [
    {
      "fmv": "11263581",
      "name": "JPM 100% US TREASURY",
      "shareOfAssets": "0.117820694646405676658259042638"
    },
    {
      "fmv": "7311921",
      "name": "COATUE OFFSHORE FUND, LTD. CLASS A SUB CLASS D TRANCHE 4 - LEAD SERIES",
      "shareOfAssets": "0.0764850549234423085941082251998"
    },
    {
      "fmv": "4361136",
      "name": "BW PRIVATE INVESTORS OFFSHORE, LTD. CLASS A - LEAD SERIES 01-18",
      "shareOfAssets": "0.0456188909164365282301155563381"
    },
    {
      "fmv": "4334740",
      "name": "ISRAEL LEGACY PARTNERS",
      "shareOfAssets": "0.045342780232286742807427034305"
    },
    {
      "fmv": "2765373",
      "name": "VIRTUS CONVERTIBLE FUND",
      "shareOfAssets": "0.0289266946112799122479324988667"
    }
  ]
}

The seal’s own scope:

  • Every figure here is the foundation's own filed return or exact arithmetic on it; nothing is estimated.
  • A 990-PF is a year-end snapshot. Prudence is judged at the time of each decision, which a filing cannot show.
  • This page neither establishes nor rules out any tax consequence, and no return is prepared or amended here.
  • A line that differs is the return's figure beside the recomputed one, as filed and as recomputed. The return may carry a reason this page cannot read: a schedule filed on paper, an election, a later amendment. It is not a finding.

We don’t prepare or file a 990-PF. We read the one the foundation filed, re-do its arithmetic exactly, and seal what it says.