Oliver Family Foundation - Page 2

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          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
               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 principal place of                  
          business was in Ontario, California, when its petition was filed.           
               William J. Tully is a promoter of tax-exempt entities, and             
          he was retained by William Shelby Oliver to form a tax-exempt               
          foundation under the control of the Oliver family.  Mr. Tully               
          formed a corporation named "Oliver Family Foundation" (petitioner           
          herein).  Petitioner's officers are Mr. Tully (vice president),             
          William Shelby Oliver (president), David S. Oliver (vice                    
          president), Evelyn G. Oliver (secretary), and Robert W. Oliver              
          (treasurer).  Petitioner's officers also serve as its directors.            
               Mr. Tully filed articles of incorporation for petitioner               
          with the Nevada secretary of state, and he prepared bylaws for              
          petitioner.  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 to prevent any Director from                   
          receiving compensation for services to the Corporation rendered             
          in a capacity other than Director."                                         

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Last modified: May 25, 2011