Janet

@leahfiles Oh mylanta!! 👀

Welcome to Part 2 of my TPUSA Fraud Playbook series, where I expose the machine, one operator at a time. Part 1 was Tyler Bowyer. Today, the worst PR guy in the game: Andrew Kolvet. In forensic work, you don't only look for what's on the form, you look for what SHOULD be on it and isn't. Andrew Kolvet is the spokesman of a $100M+ network and the executive producer of its flagship show. He appears on ZERO tax returns, ever. Not one. That's not a gap in my research. That IS the finding. 1) Andrew Kolvet is the spokesman of a $100M+ network and executive producer of its flagship show. I searched every return, TPUSA, Turning Point Action, the Endowment, America's Turning Point, every year. He is not there. Not as an officer, not as a key employee, not as a contractor. Zero. WHY BAD ACTORS DO EXACTLY THIS: the oldest move in the book is to bury the one name that touches the money AND the message. The intern is on the payroll. The man who tells millions what to think appears on not one federal form. That is what you pay lawyers for. You can't claw back what was never written down, and you can't audit a ghost. 2) So if the charity doesn't pay him, who does? The private companies. The Charlie Kirk Show, the charity's flagship media asset, is produced and monetized through Resolute Media, a for-profit LLC that Kolvet co-owns with Charlie Kirk. He also owns ATK Media outright. But none of these are reflected on the 990s. WHY BAD ACTORS DO EXACTLY THIS: this is the whole game, and it's the textbook shape of private inurement: donors and the movement build the brand and the audience with charitable money; the commercial show built on that brand is run through a for-profit the insiders own; and the revenue lands with them, not the charity. You don't take the nonprofit's money, you let the nonprofit build the asset, then you own the company that harvests it. The donors fund the machine. The insiders keep the receipts. And because it all moves through private LLCs, none of it appears on a single charitable return. Private inurement is also how a non profit can lose its tax exempt status. Paying attention, Andrew? 3) He is TPUSA's spokesman and he privately owns ATK Media, a crisis-communications and reputation-management firm. ATK appears nowhere on any Turning Point return either. WHY BAD ACTORS DO EXACTLY THIS: pick the lie. Either the spokesman's own company does the charity's PR for free, and no crisis-comms firm on earth works for exposure, or it's paid in a way built to never touch a form. A reputation firm run by the man who controls the reputation isn't a side business. It's the same job billed twice: once for the applause, once in the dark. 4) With Charlie Kirk and Tyler Bowyer, Kolvet owns a third of Resolute Media, a for-profit operating from a building on the Turning Point campus, sharing a registered agent with Superfeed, the voter-data firm Bowyer chairs. WHY BAD ACTORS DO EXACTLY THIS: three officers owning one company outright is a mirror, not a vendor. And asked in writing, under penalty of perjury, whether it did business with a company its own officers control, the charity answered “No.” So either not one dollar ever moved, or that “No” is a false statement on a signed federal return. There is no third option. 5) He didn't apply for the job. He was placed by Johnnie Moore. Kolvet was VP of Communications at The Kairos Company, the PR firm founded by Johnnie Moore, which held TPUSA as a paid client. He moved from the vendor into the client and became its permanent voice and nobody asked questions. Johnnie Moore chaired the Israel-backed Gaza Humanitarian Foundation until it was shut down, and now is an ADL board member. WHY BAD ACTORS DO EXACTLY THIS: this is how you make a paid relationship vanish. An outside PR contract is a line somebody can read. Hire that vendor's VP as your in-house voice and the same hand keeps writing the script but with no contract, no invoice, no filing, nothing. The influence didn't end, it just took off its name tag and moved into the building. 6) He appears on zero charitable returns, but he owns a Santa Barbara home bought in 2019 for $1,149,000, now worth an estimated $2.8 million, with roughly $2 million in equity and his PR company is registered at the address. Not weird at all. WHY BAD ACTORS DO EXACTLY THIS: this is the net-worth problem, the oldest tool a fraud examiner owns. When a man's assets outrun his disclosed income, you go find the undisclosed source. He runs the message of a $100 million charity, it reports paying him nothing, and he holds seven figures of California real estate. You can't see the money on the 990. You can see it in the deed. Innocent men's assets match their pay stubs. This one has no pay stub at all. 7) Within days of Charlie Kirk's death, Kolvet took over the show, the network's single most valuable for-profit commercial asset. WHY BAD ACTORS DO EXACTLY THIS: in every operation like this, the transition is when the vault sits unguarded. The founder is gone, the grief is loud, the cameras are on the funeral, and someone takes over the one asset that prints money. To be clear: the flag is who grabbed the revenue engine, not the death. This is follow the money, not Clue. 8) On January 24, 2025, Andrew Kolvet and his wife deeded their Santa Barbara home out of their own names and into the "Kolvet Family Trust." WHY BAD ACTORS DO EXACTLY THIS: a family trust is legal, common, and boring on its own. Plenty of honest people use one to skip probate. But a trust does one mechanical thing: it takes your name off the thing you own. And in Kolvet's case, we have to look at the person and the timing. This is a man who appears on zero of four charities' returns, earns through private LLCs that never touch a 990, and as January 2025, the year Kirk was assassinated, holds his one visible asset behind a trust's name instead of his own. Every layer is legal. Together they do a single job, which is to make the person who runs the message of a $100 million movement nearly impossible to find on any public document. I am not saying putting a house in a trust is a crime, because it isn't. I am saying that when every record that should carry a man's name somehow doesn't, the absence stops being an accident and starts being a method. The pattern: Kolvet is a ghost by design. He runs a nine-figure charity's narrative, owns the PR firm, owns a third of the media company, holds a piece of the show, and appears on not one page of any filing. Every dollar he makes off this movement moves through companies its own donors can't audit. That isn't sloppy paperwork, it's architecture, just a different architecture than Bowyer. But architecture still. When the head of PR in a $100 million network leaves zero trace across four nonprofits and every filing year, an auditor doesn't shrug. They subpoena. Andrew Kolvet's ATK Media, his third of Resolute, the for-profit that runs the charity's own flagship show, and that show's revenue need a forensic review. What ISN'T on the 990 is exactly what needs to be found. Bowyer is still ahead on the fraud risk matrix. I agree with that. But both warrant a forensic audit. It's becoming pretty clear to me why Charlie Kirk asked for that "DOGE like assessment" 8 days before he was assassinated.... Part 3: Stacy Sheridan, coming tomorrow

@leahfiles @IITYWWIMWYBMAD Andrew next please!

@IITYWWIMWYBMAD Oh, I will. They may get away with the other BS. But they won't escape a forensic audit, and that will be their downfall.

Let's expose the fraud playbook TPUSA's structure follows, one person at a time. First up, Tyler Bowyer. Fraud within organizations, especially when dealing with executives, is more often than not, structural. The goal isn't to steal a lump sum, it's to build a system where money moves constantly among related entities so that no single document ever shows the whole picture, insider pay is relabeled as arm's-length business expense, and the ultimate recipient is hidden behind a layer. You don't write yourself a check. You'd design exactly what I have been seeing across all TPUSA entities. Here's what Tyler Bowyer's playbook looks like: 1. On his own charity's return, Bowyer is the Chief Operating Officer AND its #1 outside “vendor”. $288,255 for “COO SERVICES,” invoiced from his house. WHY BAD ACTORS DO EXACTLY THIS: a salary gets audited and a vendor invoice doesn't. Executive pay triggers board sign-off, comparability studies, reasonableness tests, an excise tax. A “purchased service” melts into the expense pile. So you stop being an employee getting paid and start being a company getting hired by yourself. Billing it from your house is the tell: there's no firm on the other end. It's you, writing invoices to a charity you run.... 2. His pay is split across three entities. $288K from the charity, $88K from the political arm, $0 from TPUSA. Total: ~$376K. WHY BAD ACTORS DO EXACTLY THIS: everyone who might catch you pulls one filing at a time. Put the whole number on one return and it draws the excess-comp tax and the headline. Slice it across three affiliates and each piece looks modest. You're not hiding the money, you're hiding the total, and betting nobody cross-references three separate 990s. They usually don't, which is why it's one of the first things I do. 3. His public role is politics, he's COO of Turning Point Action, the (c)(4) political arm. Yet the tax-deductible (c)(3) charity pays him roughly three times what the political arm does. WHY BAD ACTORS DO EXACTLY THIS: charity money is the cheapest money in the building. It's tax-deductible, so it's easier to raise and comes in bigger amounts. If a person's real work is political and you load that salary onto the charity, you're paying for work the charity is legally barred from doing, with subsidized dollars, and the donors wrote off politics on their taxes without knowing it. You push every cost onto the entity with the cheapest money and the least scrutiny for that line. Whether this split reflects real charitable work or a misallocation is exactly what an audit would settle, and it's the first thing I'd pull his time records for. 4. The charity paying him takes 100% of its money as grants from TPUSA, spends nearly all of it, and holds nothing. In its 2023 return it booked $3.7 million in salaries against zero employees on its federal wage form. The next year it reported 124. WHY BAD ACTORS DO EXACTLY THIS: a satellite entity is a second set of books you fully control. Money leaves the closely-watched flagship as a "grant", which looks charitable, lands in a smaller entity nobody audits hard, and gets spent there on payroll and insiders with a fraction of the oversight. And millions in salaries booked against zero reported employees is the classic ghost-employee signature, wages to people who may not exist, or to insiders dressed as staff. Maybe 2023 was a filing error. That's the innocent read. But a swing from zero to 124 is the exact anomaly a forensic examiner reconciles first, because it's also how payroll fraud hides. 5. Within a few months of Charlie Kirk's assassination, as control of a nine-figure network changed hands, Tyler Bowyer opened five companies all within 54 days of one another. Four are anonymous Wyoming LLCs using one Cheyenne "mailbox". One is named “Vote LLC.” One is “Tyler Bowyer Inc.,” at the same address he already invoices the charity from. WHY BAD ACTORS DO EXACTLY THIS: the entire purpose of an anonymous LLC is that no one can prove YOU got paid. Send money to “Victory Advisors LLC” and the trail dead-ends at a mail drop. Stand up a personal corporation at your billing address and your fees now flow through a company with one more wall between the cash and your name. And you build the pipes before the money moves, right when the org is in transition and everyone's looking at the funeral instead of the filings. 6. He co-owns Resolute Media, run out of a building on the charity's campus, and chairs Superfeed, the for-profit the movement pays, with Erika Kirk's own mother on the board. WHY BAD ACTORS DO EXACTLY THIS: self-dealing is invisible when the counterparty wears a different name. You don't embezzle from the nonprofit, you sell to it, at your price, through a company you own. The charity pays “Superfeed” or “Resolute,” it reads as a normal vendor, and the profit lands with the same people who run the charity. 7. On their signed federal returns, TPUSA and Turning Point Action both answered "No" to the question regulators scan for self-dealing: any business transactions with an officer, or with a company an officer controls. WHY BAD ACTORS DO EXACTLY THIS: that box is the one you most need blank, because a "yes" invites the audit you're avoiding. And here's the defense they'll reach for, so let me get ahead of it. They'll say the "No" is technically correct: officer pay gets reported elsewhere, and this schedule only captures a company an officer owns more than 35% of. Fine. But that's exactly the problem. Those thresholds are the exits. Officer comp is excluded. A 34% stake is excluded. So a person can be paid by the charity, own a slice of the vendors it hires, and chair a company it does business with, and still, truthfully, check "No." The schedule built to expose insider dealing has doors an insider can walk right through. A "No" here doesn't mean there's nothing to see. It means the only way to see it is the one thing they haven't handed over: the ownership percentages and the payment records. That, again, is the audit. The pattern: Every one of these findings align to what someone committing fraud would do and reveals a behavioral pattern: to make the money harder to see, the recipient harder to name, and the total harder to add up. Real fraud isn't loud. It's a hundred small, individually-defensible decisions that all lean the same way, toward the insiders and away from the light. One of these could be considered a "quirk", but all seven, across every entity, for years, it is a design. I can't prove intent from a tax form. Intent lives in the bank records and the operating agreements, and those aren't public. But every structural choice here is the one a person with something to hide would make. That is the reason to open the books. Tyler Bowyer (and all of TPUSA, but I'll get there in the following parts) needs a real forensic audit, by the IRS, by the Arizona AG, by anyone with the subpoena power to pull what a 990 will never show you. They built the structure betting nobody would read the filings or pay attention. I'm paying attention. Part 2 coming next. Who do you want? Erika Kirk or Andrew Kolvet?

@leahfiles Gurrrl! I’m here for it! You did an amazing job! Well done!