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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 construed
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