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FINDINGS OF FACT
When their respective petitions were filed, Larry
Whittington resided in North Charleston, South Carolina, and Ray
and Glynda Whittington resided in Greensboro, North Carolina.
During the years in issue, Larry and Ray worked for Fountain
of Life, Inc. (FOL), an evangelical organization established by
their brother Jim Whittington. On January 1, 1976 and 1977,
respectively, Ray and Larry were ordained as ministers of the
Gospel by FOL. In addition to their ministerial duties, Ray was
employed as FOL's secretary-treasurer, Larry was employed as
FOL's vice president, and both were members of FOL's board of
directors.
During the years in issue, FOL presented the Gospel through
services, crusades, and publications. Daily services were
conducted by Jim, Larry, and Ray and included sermons, songs, and
the distribution of religious materials (e.g., pamphlets, books,
albums, and cassettes). Jim, Larry, and Ray routinely officiated
at marriages and funerals and provided counseling to FOL members.
FOL had members who were not associated with any other religious
organization or denomination. In addition, FOL conducted several
crusades each month and developed a loyal group of followers.
Some of the crusades were videotaped and later broadcast on "The
Fountain of Life Presents Jim Whittington" television program,
which at its peak was broadcast in 75 television markets.
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