Homer L. Richardson - Page 17

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               Throughout the years in issue and continuing to the present,           
          Mr. Richardson made all of the day-to-day investment decisions              
          with respect to, controlled all of the assets being held by, and            
          had complete supervisory control over HGAMC and HGRCT.                      
          Tax Reporting                                                               
               For each of the years in issue, petitioners filed: (1) A               
          joint Form 1040, U.S. Individual Income Tax Return, for                     
          themselves and including a Schedule C, Profit or Loss From                  
          Business, for Asset Protection Services; (2) a Form 1041, U.S.              
          Income Tax Return for Estates and Trusts, for HGAMC; and (3) a              
          Form 990-PF, Return of Private Foundation or Section 4947(a)(1)             
          Nonexempt Charitable Trust Treated as a Private Foundation, for             
          HGRCT.  Wilson M. Graham (Mr. Graham) of Graham & Associates                
          signed each of the foregoing returns, except the 1996 Form 1040,            
          as preparer.  Mitchell Graham, also of Graham & Associates and              
          Mr. Graham’s son, signed the 1996 Form 1040.7  As indicated by              
          the workshop announcements quoted above, Mr. Graham was involved            
          in promotion of the Aegis trust system.  The 1996 Form 1040 was             
          filed on April 15, 1997, and the 1997 Form 1040 was filed on                
          September 23, 1998.                                                         




               7 Mr. Graham was formerly licensed as a certified public               
          accountant in the State of Ohio, but his license was revoked in             
          1994.  No evidence reflects that Mitchell Graham was at any time            
          licensed as a C.P.A., and testimony indicated that he was not.              





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