John W. Madden, Jr., et al. - Page 6

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          during 1985 and 1986, secretary/treasurer during 1987, and                  
          secretary during 1988 and 1989.  Petitioner's daughter served on            
          the board of directors of the Museum during all the years at                
          issue.  She was the secretary of the Museum from 1983 through               
          1985, president of the Museum during 1986, and president/vice               
          president from 1987 through 1989.  Both petitioner's wife and               
          petitioner's daughter were foundation managers of the Museum                
          under section 4946(b) during the years at issue.                            
               The Museum, an "outdoor" museum which can be best described            
          as a "museum without walls", was granted its tax-exempt status              
          under section 501(c)(3) on September 3, 1982.  The principal                
          purposes of the Museum, as set out in its Articles of Amendment,            
          include the "stimulation, promotion and development of the                  
          interest of the general public in every manner of art forms                 
          through organization and operation of outdoor and indoor museums,           
          the holding and sponsorship of music concerts, art exhibitions              
          and theatrical and dance performances, all for cultural and                 
          educational purposes".  The Museum's artwork consists primarily             
          of sculptures and other exhibits that are designed to withstand             
          the outdoor elements.  Although a few pieces are located in                 
          public atria inside some of the buildings, most of the artwork is           
          situated along the public thoroughfares that run throughout the             
          Greenwood Plaza complex.  The Museum conducts tours of its art-             
          work and also offers courses in art to members of the community.            






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