- 4 - Service in the assessment and collection of Federal income taxes through the marketing through IBA of trusts similar to Ideal Management. His conviction was affirmed on appeal. See United States v. Scott, 37 F.3d 1564 (10th Cir. 1994). On April 3, 1989, petitioner transferred his business property, including work tools and two vehicles, to Ideal Management in exchange for 100 capital units. Petitioner retained beneficial use of the transferred property after the transfer. On the same day, petitioner agreed with Ideal Management to provide his floor installation services as an independent contractor of Ideal Management in return for its paying him $300 per month. On December 28, 1990, petitioner and Ideal Management amended this agreement to provide that petitioner would receive $400 per month, and that petitioner could not be "terminated" without 30 days' written notice. Petitioner transferred his capital units to Clark on April 4, 1989. Petitioner was Ideal Management's only floor installer during 1992, and his labor generated over $70,000 in revenue during that year. Petitioner worked full time for Ideal Management during that year at the rate of $400 per month, and Ideal Management paid him $4,600 in toto. Petitioner's 1992 Form 1040 reported $4,620 of gross income, consisting of the $4,600 from Ideal Management and $20 of interest income. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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