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The Whittingtons created a production plan for FOL events.
To execute this plan, Larry founded Lovejoy Agency, Inc.
(Lovejoy), a for-profit corporation, and Larry served as its
president and a member of its board of directors. Lovejoy
purchased television, radio, and newspaper advertisements for FOL
events; made travel arrangements and leased facilities for FOL
events; and produced FOL's television shows, albums, and
cassettes.
To fund FOL operations, FOL solicited contributions through
mass mailings. The mailings were also used to inform FOL members
of scheduled FOL events, such as crusades, in their geographic
area. FOL mailed approximately one-half million pieces of mail a
month. To produce these mailings, Ray founded Whittington, Inc.,
a for-profit corporation. Whittington, Inc., bought equipment
and prepared the mass mailings on behalf of FOL in exchange for
fees from FOL.
During the years in issue, FOL paid Larry and Ray salaries,
housing allowances, and other benefits (i.e., travel
reimbursements, football tickets, and scholarship pledges). The
salaries and housing allowances were authorized by FOL's board of
directors before payment. The following chart delineates the
payments from FOL to petitioners.
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Last modified: May 25, 2011