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connection with three payments in the amounts of $2,304, $1,343,
and $3,000 made by the Museum.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are incorpo-
rated herein by this reference. Petitioner and petitioner's wife
resided in Englewood, Colorado, at the time he filed his
petition.3
Petitioners
Petitioner formed the John Madden Co. (the Company) in 1969.
The Company, which develops and manages commercial office
buildings and office parks, played an integral role in developing
Greenwood Plaza, a Denver, Colorado, office complex consisting of
49 commercial office buildings spread over 200 acres of land.
The Company, via a number of different partnerships, owned nine
of the buildings in the complex during the years at issue.
The Museum, a private foundation incorporated in the State
of Colorado, is located in the Greenwood Plaza complex. Peti-
tioner is one of the founders of the Museum and was a foundation
manager of the Museum under section 4946(b) during the years at
issue. Petitioner's wife served as treasurer of the Museum
3Cynthia Madden Leitner (petitioner's daughter) resided in
Littleton, Col., at the time she filed her petition. The
principal place of business of GMC and the Museum of Outdoor Arts
(the Museum) was Englewood, Col., when they filed their
petitions.
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