Robert A. and Colleen L. Lund - Page 5




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               On July 1, 1994, Sun Federal, a corporation owned by Owen              
          Charles, another promoter of trust schemes similar to that of               
          Zero Gee, apparently replaced Bigelow Charter as the corporate              
          trustee of Zero Gee.                                                        
               Under terms of the Zero Gee trust document, the trustees of            
          Zero Gee were to manage, operate, and control Zero Gee for the              
          benefit of the beneficiaries.  During the years in issue,                   
          however, neither the corporate trustee of Zero Gee nor Loren and            
          Bonnie Troescher were involved in any significant way in the                
          management, operations, and control of Zero Gee or LPS.  Zero Gee           
          paid Sun Federal a total of only $3,600 a year for Sun Federal’s            
          alleged services as trustee of Zero Gee.                                    
               Under terms of the Zero Gee trust document and other trust             
          materials:                                                                  

               (1) The trustee was authorized to make noninterest                     
               bearing loans to the Lunds; and                                        
               (2) Written approval of the trustees allegedly was                     
               required for trust expenditures in excess of $5,000.                   

               Any approval requirement, however, under (2) above was                 
          rescinded on January 30, 1994.                                              
              After the purported transfer of LPS to the Zero Gee trust              
          and through at least 1996, petitioner continued to manage,                  
          operate, and control the business of LPS and Zero Gee.  The                 
          business was conducted in the name of LPS and in essentially the            






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