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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,
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. The
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