Larry D. Bowen Family Found. - Page 2




                                        - 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 construed             







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011