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(5) foreign trusts in Belize acted as beneficiaries of the
purchasers' trusts, and the foreign trusts owned the capital
units;
(6) the purchaser was never the named capital unit holder;
(7) each trust was established by a fictitious domestic
trust, named "Cache Properties", for a nominal amount of $100;
(8) the second trust was usually a foreign trust with a
trustee named Dennis Smith;
(9) a purchaser could ensure perpetual control of his or
her trust by naming himself or herself as secretary or manager;
(10) a purchaser could not be removed or fired except with
30 days' notice; and
(11) the trusts were "sold" by IBA for $2,500 apiece.
Following our detailed review of the facts surrounding Ideal
Management, with our knowledge of the facts in Scott, we reach
the conclusion that Ideal Management was devised and operated
similarly to the trusts examined in Scott. We conclude that
Ideal Management, like the trusts in Scott, was a sham. Accord
Hanson v. Commissioner, 696 F.2d 1232 (9th Cir. 1983), affg. T.C.
Memo. 1981-675; Markosian v. Commissioner, 73 T.C. 1235 (1980);
Dahlstrom v. Commissioner, T.C. Memo. 1991-265, affd. without
published opinion 999 F.2d 1579 (5th Cir. 1993); Dahlstrom v.
Commissioner, T.C. Memo. 1991-264, affd. without published
opinion 999 F.2d 1579 (5th Cir. 1993).
Our conclusion is strengthened by our analysis of a number
of factors that this Court has previously considered to help
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