John W. Madden, Jr., et al. - Page 5

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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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