Forest L. Buckmaster - Page 4

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            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,                                
                  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.  The                                

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