Zach from WolvesAndFinance Exposes Financial Irregularities at Turning Point USA Involving Tyler Bowyer and Jake Hoffman
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Zach from WolvesAndFinance Exposes Financial Irregularities at Turning Point USA Involving Tyler Bowyer and Jake Hoffman
Zach from WolvesAndFinance continues his investigation into financial irregularities at Turning Point USA, focusing on 110 LLC, a company receiving millions through a UPS store mailbox. He examines the connections between Arizona State Senator Jake Hoffman, Tyler Bowyer, and suspicious money flows totaling $4.7 million. The investigation reveals contradictory statements, unexplained wealth, and secret shell companies formed in Delaware. Despite mounting questions about kickbacks and financial impropriety, Turning Point's leadership refuses to conduct the independent audit that Charlie Kirk requested just days before his death. Zach explores Tyler Bowyer's sudden acquisition of $650,000 in cash, mysterious donations to political campaigns, and a pattern of suspicious business dealings dating back to 2017.
Zach from WolvesAndFinance has been conducting a series of investigations into financial irregularities at Turning Point USA. After his initial videos, people within Turning Point have responded to his allegations. In this analysis, he addresses their comments while revealing shocking new information about the flow of millions of dollars through questionable business entities.
The investigation centers on a company called 110 LLC, listed as one of the top independent contractors for Turning Point with payments totaling $1.5 million according to IRS disclosure forms. Zach tracked down the address for 110 LLC to a parking lot of a strip mall, an address also listed in the financial disclosure statement of Arizona State Senator Jake Hoffman.
The UPS Store Mailbox Mystery
Following viewer feedback, Zach acknowledges the most likely explanation: the money is being sent to a UPS store mailbox in that strip mall, not the parking lot itself. However, Turning Point has not confirmed this basic fact, choosing instead to remain silent on the issue.
What Zach finds extremely disturbing is that since these questions have been raised, not a single person from the accounting department at Turning Point has made any statements. The chief financial officer, Arizona State Representative Justin Olsen, has said nothing. Instead, the only responses have come from marketing personnel like Andrew Kolvet, Blake Nef, and Tyler Bowyer. Zach questions whether the accountants remain silent because they know anything they say could be used against them in a court of law.
Arizona State Senator Jake Hoffman has made seven posts on X.com confirming he uses the UPS store mailbox for 110 LLC. In one post, he states: "110 is a decade old marketing company with many clients. The address I use for mail and public disclosures is a UPS store private mailbox at that address." However, Zach identifies this as a massive lie, providing documentation that the company was formed in 2021, just four years ago, not a decade ago.
Strangely, in all seven of Hoffman's posts defending himself, he never mentions Turning Point USA—the organization that sent $1.5 million to his company. The only evidence this company exists is a UPS store mailbox where millions of dollars are being delivered.
Operating a Multi-Million Dollar Business From a Mailbox
Zach returns to the strip mall parking lot to show viewers the actual UPS store mailbox. He explains his hesitation in making this connection stems from the massive implications. While small businesses commonly use UPS store mailboxes, this situation is different. This is an Arizona state senator operating a multi-million dollar business with no physical location or evidence of existence beyond this mailbox.
Zach corrects a mistake from his previous videos: there is a website for 110 LLC at 110.io. However, the website raises more questions than it answers. It consists of literally one page featuring a sample marketing example with Turning Point Action listed on the ad. Zach finds it suspicious that Hoffman appears to be advertising that if you pay him money, you also get the support of Turning Point Action.
Using the Wayback Machine reveals the website has not changed at all since 2021. This supposed marketing company has not made a single update to its website in years. Even more telling, the website is not indexed by Google—if you search for it on Google, you receive zero results. What kind of marketing company has a website that cannot be found through search engines?
Security Concerns or Shield from Scrutiny?
Jake Hoffman has explained that he does not give out the address or details of his operations because of political persecution from what he calls "the insane murderous left." Zach rejects this explanation. As a state senator, Hoffman must prove he is not taking bribes. He cannot claim security reasons as a shield to stop anyone from knowing the details of his suspicious business dealings.
Zach draws a comparison: this would be like Donald Trump deciding not to let anyone know the addresses for his hotels or anything about his golf courses for security reasons. That would be ridiculous. Public officials who choose to live a public life do not get to keep their businesses giant secrets. There is nothing wrong with a state senator running his own company, but it has to be an actual business and not a way to launder money.
Even assuming Jake Hoffman is completely innocent, Zach argues this is still a stupid thing to do. Just for appearance's sake, it looks shady. He draws a parallel: imagine if Joe Biden had a UPS store mailbox where people walked in and dropped off millions of dollars. In fact, Joe Biden did have multiple shell companies that didn't seem to do anything, and Congress held hearings about it for two years. Zach questions why Republicans who got upset over Biden's shell companies don't want to talk about what Jake Hoffman is doing.
Following the Money Trail
Using transparencyusa.org, which shows election-related expenditures in US state elections, Zach reveals that 110 LLC received over $4 million from Arizona election campaigns and a small amount from Wisconsin campaigns. This figure represents only a portion of the revenue reported as part of state elections—the actual revenue numbers are much higher because this doesn't include all the money paid by Turning Point.
Another key figure in this investigation is Tyler Bowyer, the COO of Turning Point Action and America's Turning Point. Tyler Bowyer is important because the Turning Point shell companies he managed happen to be the same shell companies paying 110 LLC.
Zach shows clips of Tyler Bowyer describing how he first met Charlie Kirk, saying he would "hitch his wagon" to Charlie Kirk and calling himself Charlie Kirk's best friend. Boyer also describes himself, Charlie Kirk, and Candace Owens as "the three amigos," claiming he was present the day Candace met Kanye West.
Contradictory Accounts and Trust Issues
However, Zach contrasts Boyer's version of events with what Candace Owens has said about Tyler Bowyer. In a clip, Candace states: "It did make sense to me that Tyler Bowyer lied about it and I don't trust Tyler Bowyer and that is never going to change. Similarly with Rob McCoy, he makes my skin crawl. I can't explain it. I look at him and he's a bad person and nobody can make me feel one way or the other about that."
Candace says she does not trust Tyler Bowyer and compares him to Rob McCoy, who she says makes her skin crawl. Zach asks: which one is it? Were they the three amigos, or is Candace correct in saying Tyler Bowyer cannot be trusted?
A Pattern of Shell Companies
Zach takes viewers back in time to 2017 when a company called We the People USA, Inc. was created as a nonprofit corporation in Arizona. Understanding what people have done in the past becomes a template for what they're likely to do in the future. This company was created with five directors: Mike Miller, Doug DeGroot, Jake Hoffman, Dwayne Farnsworth, and Tyler Bowyer.
Mike Miller and Doug DeGroot are both current board members of Turning Point USA. Dwayne Farnsworth is a bankruptcy attorney in Mesa, Arizona, which Zach finds strange—why is this random bankruptcy attorney a director in this company with Jake Hoffman and Tyler Bowyer?
Zach notes that Dwayne Farnsworth has the same last name as Terryl Farnsworth, the IT guy who was present at Charlie Kirk's murder. While he doesn't know if these two people are related, he points out that many people have questions about Terryl Farnsworth's behavior. Why did he move the chair at the crime scene to remove the SD cards with the footage of the murder? Why did he film a selfie video of himself directly after the shooting, saying "He's dead" on camera? Zach finds it extremely strange that someone who witnesses a shooting would immediately think to film a selfie video of themselves.
The main point is to demonstrate that Tyler Bowyer and Jake Hoffman have a history of doing side businesses together. We the People USA, Inc. was formed in 2017 and then dissolved in 2021. Notably, 110 LLC was created in 2021. Zach presents the formation paperwork signed by Jake Hoffman, questioning why Hoffman lied in his post on X.com claiming it was a decade-old company when it was actually formed just four years ago.
The company was formed at an address in Delaware next to several other buildings Candace Owens has identified in her podcast. The Delaware address Jake Hoffman is using is for Incorp, which is listed on Delaware's website as a registered agent who can set up shell companies. Zach asks: why does all this shady stuff happen in Delaware?
Tyler Bowyer's Unexplained Wealth
At the same time the old company was being shut down in Arizona, this new company was being formed in Delaware. Because it was formed in Delaware, all the partner information is kept secret. Zach believes it is reasonable to suggest that Tyler Bowyer was likely involved in the creation of 110 LLC. If Tyler Bowyer is a partner, that means he would receive a share of the profits of every dollar that flows through that UPS store mailbox.
Zach mentions that Tyler Bowyer lives in a massive mansion with multiple buildings, a pool, and a private basketball court. His address is listed on IRS Form 990. The shocking revelation comes from the paperwork showing when Boyer bought his house—it was purchased in 2021, four months after 110 LLC was created. The property was worth $1.95 million, and he put down a payment of $650,000.
The timeline is stunning. Court paperwork from 2017 shows Tyler Bowyer was involved in a lawsuit over unpaid fees from a condo development, a case he had been fighting since 2010. The court order states the exact condition of the judgment was $11,041.32 as of June 8, 2017. Tyler Bowyer owed this money and was taken to court. News reports indicated his wages were garnished because of this debt.
As of 2017, Tyler Bowyer was struggling financially—this is not the type of situation you see from someone who has significant wealth. This raises the obvious question: how did he get $650,000 in cash to use as a down payment on his house just four years later? Zach asks viewers if they find it suspicious that someone who was broke in 2017 could have $650,000 in cash by 2021. Tyler Bowyer needs to answer the simple question: where did he get the $650,000?
The Kari Lake Connection and Mystery Donation
The first major customer of 110 LLC was Kari Lake when she was running for governor of Arizona. Kari Lake had a super PAC called Put Arizona First. Right before the primary, Put Arizona First received a $2.3 million donation. The super PAC then turned around and gave the entire $2.3 million to 110 LLC.
To this day, the source of this $2.3 million donation remains unknown. It came from a company called PH Medical LLC. While there is a company in California called PH Medical that sells medical supplies, this is not the same company. PH Medical LLC is another shell company out of Delaware, and everyone involved in the company is kept secret. Nobody knows where the money came from.
Zach finds this outrageous. The American people deserve to know who gave $2.3 million to Kari Lake. Someone at Turning Point, Kari Lake's campaign, or among the Republican elite must know who gave this money and why it all ended up going to a UPS store mailbox for 110 LLC.
Kari Lake won the primary election, but interestingly, her official campaign did not hire 110 LLC to do their marketing for the general election. Lake hired major legitimate marketing companies with active websites, offices, and employees. She still continued to pay 110 LLC, but at a much lower level, and she ended up losing the general election.
This marked the start of many different campaigns that 110 LLC received money from in Arizona politics. For instance, one customer was David Farnsworth, with Turning Point Action creating posters supporting him. Zach questions why all these people with the last name Farnsworth are doing business with Tyler Bowyer.
The Growing Total: $4.7 Million Through a Mailbox
Multiple candidates paid money to the UPS store mailbox for 110 LLC while Turning Point was also supporting their election campaigns. It appears they are all working together. The problem is that if any Turning Point employees are also receiving money from 110 LLC, that would constitute kickbacks—Turning Point employees getting rich off these election campaigns.
Zach acknowledges he doesn't have direct evidence of this, but points out that a simple question could provide answers: are any Turning Point employees receiving money from 110 LLC?
This financial infrastructure was already in place when Charlie Kirk was murdered. The old company was closed, the new company was formed in Delaware, suddenly Tyler Bowyer had $650,000 in cash, and 110 LLC received $2.3 million from Kari Lake's super PAC. The obvious question: did any of that $2.3 million somehow make it into Tyler Bowyer's pocket?
There is another shell company that hasn't been fully discussed yet: Turning Point PAC. This is a political action committee, and Tyler Bowyer's Instagram profile shows he is also involved in this company. By looking at opensecrets.org, which tracks how Turning Point PAC spends money on federal campaigns, the pattern continues. The majority of the expenditures for Turning Point PAC are being sent to the UPS store mailbox for 110 LLC. They paid $1.1 million in the 2021-22 election cycle and $2.1 million in the 2023-24 election cycle.
Keeping track of the totals, the amount of money Turning Point has sent to 110 LLC has now increased from the originally reported $1.5 million to $4.7 million. How is this Arizona state senator with no office helping out on all these federal campaigns? Zach questions whether he is the only person who finds it crazy that millions of dollars are flowing through this UPS store mailbox.
Where is Arizona's Attorney General?
The person who could answer these questions easily is Arizona Attorney General Kris Mayes. She could issue a subpoena for the accounting records at 110 LLC and Turning Point and provide answers to everyone's questions. Since people have been raising these questions, she has done nothing. Zach questions what she does all day and whether she will look into the questions about Turning Point, asking if the public could at least get a strongly worded statement from her.
Charlie Kirk's Final Memo
Fast forward to the time period before Charlie Kirk's murder. In previous videos, Zach pointed out strange things happening in the financials at Turning Point during the months leading up to the murder. There was an unusual transfer of $8.6 million from Turning Point USA into Tyler Bowyer's shell company, America's Turning Point. There was an unusually high employee expense for Tyler Bowyer's shell company that still cannot be explained. Money continued flowing from Tyler Bowyer's shell companies to 110 LLC.
Zach believes these transactions culminated in the memo that Charlie Kirk issued eight days before he was murdered, in which he appointed a new COO of Turning Point USA, Justin Strife, and requested a new "Doge style" audit. Anyone who has worked in corporate America knows what that memo implies—it is the typical memo you see when you discover someone is stealing money from the company. You replace their position, start a new audit, and work on moving that person out of your company.
Tyler Bowyer's Defense and Contradictions
Tyler Bowyer has responded to this allegation with a post on X.com stating: "Made up. I haven't been COO of TPUSA for over 3 years. You're listening to people making things up." He posted a screenshot of his LinkedIn profile as evidence, showing he was the chief operating officer of Turning Point Action since July 2022, implying he had nothing to do with Turning Point USA or Charlie Kirk's memo.
Zach finds Tyler Bowyer's post ridiculous. To his knowledge, since Boyer's title change in 2022, no one has held the position of COO at Turning Point USA until Charlie Kirk's memo appointing Justin Strife. Anyone who has worked in corporate America knows that if you get a title change and no one backfills your position, you still end up doing your old job. It is still likely that Charlie Kirk's memo was attempting to minimize Tyler Bowyer's influence at the company.
Even more compelling, Tyler Bowyer's post is contradicted by his own words. The Washington Post obtained a secret audio recording of Tyler Bowyer from late 2022, after his supposed title change. In the recording, he states: "I'm happy to share with you the history of Turning Point USA because I've learned the whole thing from the bottom up. So you do realize you're talking to the guy that basically runs everything."
He is talking specifically about Turning Point USA, not the other shell companies, and says he is "the guy who basically runs everything." These are Tyler Bowyer's own words months after he supposedly changed his title. Zach asks: which one is it, Tyler? Were you lying then or are you lying now? Or are you just lying all the time?
The Washington Post also recorded Tyler Bowyer saying: "And honestly, I have giant balls and I don't care. I'll walk in and talk to anyone. I'm a transparent piece of glass here on everything that I do and everything I'm involved with." Zach notes that Boyer does not sound like a very nice person, and if he's so transparent, why doesn't he explain why he is sending $4.7 million of Turning Point's money to a UPS store mailbox?
Erika Kirk Refuses the Audit
What makes all of this suspicious is the actions of Erika Kirk. She still refuses to do Charlie Kirk's final wish that he wrote in that memo—a Doge-style audit of the finances at Turning Point. This would be easy to do: bring in an independent third party, which takes a couple of months and would calm everyone's concerns over the finances. Why does she refuse to do an audit? The only reason Zach can think of is that it will uncover criminal activity.
When Erika Kirk is asked about the issues at Turning Point, she references chapter 6 in the book of Nehemiah, where he is building a wall and the townspeople are calling him names, asking him to come down. Nehemiah had the same message four times in a row: "I cannot come down. I am busy building." Erika says that is how she feels—she does not have time to address the noise. Her silence does not mean she is complacent, and it doesn't mean that Turning Point USA and all the handpicked staff that loved her husband and that her husband loved are somehow "in on it."
Zach responds that apparently they cannot ask about the finances because of a Bible verse. He counters with his own Bible verse—Proverbs 29:1: "Whoever stubbornly refuses to accept criticism will suddenly be destroyed beyond recovery." Turning Point is a taxpayer-subsidized nonprofit. The public has every right to demand the CEO answer questions about obvious financial irregularities.
The Baker Tilly Audit Limitation
Turning Point keeps claiming they already do an annual financial audit with the accounting firm Baker Tilly. In the opinion letter from Baker Tilly, they say nothing is wrong and there are no problems at Turning Point. But sometimes annual audits miss things—they make mistakes too. If they did miss something, they are actually incentivized not to report it because then it makes them look bad. That is why it is a good idea to rotate audit firms occasionally to new firms.
Bringing in an additional Doge-style audit would be such an easy, simple thing for Erika Kirk to do. It's clearly what Charlie Kirk wanted. Zach finds it extremely suspicious that she still refuses to do an audit.
Circumstantial Evidence and the Call for Whistleblowers
To be clear, all of this is circumstantial evidence. Currently, Zach does not have any direct evidence of a crime. But the real question is this: given all the facts he has laid out, what is the more likely possibility? That Tyler Bowyer is completely innocent or that he's doing something shady?
If viewers have more information about the finances at Turning Point and want to be a whistleblower, they can email Zach directly at tips@wolvesandfinance.com. This email goes directly to him and he can keep information anonymous. One thing he's looking for right now is information about why the salary expense for America's Turning Point is so high. He already has some information about this, but would like more.
Defending the Right to Ask Questions
Zach realizes he's going to receive hate for this video. Many people have been frustrated at anyone who criticizes Turning Point, thinking it is bad to have any fighting in the Republican party. He believes they're greatly misjudging the American people. Americans like to see debate. They want to see a party where people are free to disagree with each other. He thinks this is actually good for the Republican brand.
Zach challenges viewers: try going to a Democrat meeting and ask questions about transgender surgeries on children. You will be thrown out of that meeting so fast because you are not allowed to ask questions. The American people hate that. They want to be part of a party where people ask questions.
People want to see Turning Point managing their finances responsibly. They want to see an audit. This is a good thing for Republicans because there is nothing that makes you feel more like an American than asking questions. Zach asks viewers to share their opinion: do you think Erika Kirk should do a Doge-style audit?
