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suit, involving the Gordons, the judge found, among other things:
“The * * * [1994 conviction] involved the same facts and
circumstances for which the Plaintiffs obtained their
judgment[s], i.e., failing to pay taxes on the money Mr. Mueller
stole from investors such as the plaintiffs. * * * The Trust
[trust] is funded by money fraudulently conveyed to it by
Reinhard and Christa-Karin Mueller.” We think those statements
are probative of the fact that the trust was funded with
husband’s unreported items of income for 1986.
Petitioner testified as follows: The stocks and bonds
transferred to the trust were her “savings”. Her savings were
the result of her frugality as a housewife. Her savings were
money she has set aside for retirement. At the time the trust
was established, she had “a few” stocks and bonds. She does not
know the difference between a share of stock and a bond, and she
could not remember the quantity or name of any of the stocks and
bonds that funded the trust. Her husband had put the money into
the trust, and she did not know how much money went into the
trust. She did not keep track of the value of the trust, and, at
the time of trial, did not know the trust’s value. She did not
receive accountings from the trustees.
Petitioner did not comply with a subpoena for documents
relating to the trust. Moreover, we found petitioner’s testimony
regarding the establishment and operation of the trust to be
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