David Rendel and Rachel Rendel - Page 4

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                    advised Howard and petitioners regarding the purported tax                                                                                             
                    benefits of offshore trusts.                                                                                                                           
                              In 1982, with the assistance of Howard, Armstrong, and                                                                                       
                    Green, petitioners established an ALA-type of offshore trust                                                                                           
                    program.  Five sham trusts were established and domiciled in                                                                                           
                    Grand Turk, the capital of the Turks and Caicos Islands, located                                                                                       
                    in the British West Indies, under the names of five shell                                                                                              
                    companies (namely, DCH Management (DCH), Ledner Consulting Co.                                                                                         
                    (Ledner), DARA Co. (DARA), Cosmos Investment Co. (Cosmos), and                                                                                         
                    Alpha Associates (Alpha)).                                                                                                                             
                              Bank accounts were then opened in California, one account                                                                                    
                    each under the name of four of the five trusts.  Howard was a                                                                                          
                    trustee and an agent for Alpha, and Howard held signatory                                                                                              
                    authority over the DCH, Ledner, DARA, and Cosmos bank accounts.                                                                                        
                              An interest-bearing investment account was also maintained                                                                                   
                    in California under Alpha’s name with the Capital Preservation                                                                                         
                    Fund of the First Interstate Bank of California (the Alpha                                                                                             
                    account).  The Alpha account was maintained under CCMI's                                                                                               
                    corporate identification number.  Rachel held signatory authority                                                                                      
                    over the Alpha account.                                                                                                                                
                              Pursuant to petitioners' offshore trust program, funds                                                                                       
                    transferred into the trusts represented profits realized by CCMI.                                                                                      
                              During 1982 and 1983, $174,308 in profits of CCMI was                                                                                        
                    transferred from CCMI through the offshore trusts and ultimately                                                                                       
                    to the Alpha account.  With Howard's participation, the profits                                                                                        




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