Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 19

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               Although the McKenzie Trust was ostensibly engaged in the              
          business of restoring Model T Fords, it was petitioner who worked           
          full time to order automotive parts from suppliers, to purchase             
          rusted Model T Ford chassis, and to restore them into finished,             
          operable, and safe Model T Ford speedsters for resale at                    
          auctions.  Mr. Boatright signed checks from the trust’s bank                
          account in advance so that petitioner could fill them out when he           
          purchased automobile parts.  The McKenzie Trust had no employees            
          other than petitioner, and all of the income earned by the                  
          McKenzie Trust was attributable to petitioner’s labor.  No agent            
          of Glenmere Investments was ever involved with the automobile               
          restoration business allegedly conducted by the McKenzie Trust.             
               Petitioner filed Forms 1041 for the taxable years 1995                 
          through 1998 in the name of the McKenzie Trust, which were signed           
          by Mr. Boatright.  The 1995 and 1996 returns claimed income                 
          distribution deductions for amounts allegedly distributed to                
          Glenmere Investments, and the trust did not pay any income taxes            
          in 1995 or 1996.  On the McKenzie Trust’s 1996 return,                      
          petitioner’s management fees were deducted on Schedule C, Profit            
          or Loss From Business, as legal and professional services in                
          computing the trust’s income that was distributed.  For the                 
          taxable year 1997, the management fees paid to petitioner                   
          exceeded the McKenzie Trust’s income, and, as a result, the                 








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