- 2 - Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. Background We decide this case on the basis of the entire administrative record, see Rule 217(b)(1), which is incorporated herein by this reference. Petitioner's mailing address was in Ontario, California, when its petition was filed. William J. Tully is a promoter of tax-exempt entities. Larry Don Bowen and his wife Virginia (collectively, the Bowens) attended one of Mr. Tully's seminars and later paid him to form a tax-exempt family foundation for them. Mr. Tully formed a corporation named "Larry D. Bowen Family Foundation" (the petitioner herein), with five "members", five directors, and four officers. The corporation's officers are the Bowens, Mr. Tully, and the Bowens' son, Michael Bowen. The corporation's directors are the same four officers and the Bowens' other son, Larry Albert Bowen. The corporation's "members" are unidentified. Mr. Tully filed articles of incorporation and bylaws for petitioner with the Nevada Secretary of State. The articles state that petitioner's primary purpose is "TO PROVIDE FINANCIAL ASSISTANCE FOR THE NEEDY." The bylaws state that petitioner's primary purpose is that set forth in the articles. The bylaws further state that "Nothing herein contained shall be construedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011