Ray W. and Marilyn S. Sowards - Page 5

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          STL’s place of business.  Mr. Sowards went to his STL office on a           
          regular basis.                                                              
               Mr. Sowards, STL, and Mr. Strong had a close business                  
          relationship.4  Mr. Sowards, Mr. Strong, and STL referred clients           
          among themselves.  Mr. Sowards performed legal services for STL             
          and advised many of STL’s clients.5  Mr. Sowards traveled and               
          assisted Mr. Strong with seminars promoting STL’s services                  
          conducted in Ohio, Hawaii,6 Alaska, and Texas.  STL reimbursed              
          Mr. Sowards for business and travel expenses.  STL also provided            
          Mr. Sowards with an American Express credit card.                           
               On or about June 1, 1994, Mr. Sowards, with the assistance             
          of Mr. Strong, purportedly created an intervivos trust named                
          Wealth Preservation Assistance (WPA).  Mr. Sowards was the sole             
          grantor of WPA.7  The trust document states that WPA’s business             
          purpose is “diversification of business activities and business             
          assets for planned constructive growth.”                                    


               4Petitioner Marilyn Sowards (Ms. Sowards) testified that Mr.           
          Strong and her husband had a contract relationship.                         
               5Mr. Sowards testified that he performed these legal                   
          services as a courtesy and on a pro bono basis.                             
               6In one of the years at issue, Mr. Sowards traveled to                 
          Hawaii as many as nine times to assist Mr. Strong with the STL              
          seminars.                                                                   
               7Mr. Sowards testified that there were three main reasons              
          for establishing WPA:  (1) For use in doing charitable, pro bono            
          legal work; (2) for use on some minor business transactions; and            
          (3) for use in estate planning.  WPA was never used for                     
          charitable purposes or as a business entity.                                




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