- 8 -
and found that these trusts were fraudulent. Id. at 1572. The
Court of Appeals set forth an extensive analysis of these trusts,
all of which were remarkably similar to Ideal Management.
Suffice it to say that petitioner misread Portillo v.
Commissioner, supra, if he truly believes that Portillo stands
for the broad proposition that the determination at hand was
"naked" because respondent did not actually audit Ideal
Management.
We find that Ideal Management was merely a device conjured
up for petitioner and other taxpayers seeking to avoid Federal
income tax. Petitioner testified that he was not tax motivated
when he joined Ideal Management, and that he joined Ideal
Management mainly to protect his assets from creditors.
Petitioner testified that he transferred to Ideal Management his
entire ownership interest in his assets so that his personal
creditors would not be able to seize them if he was ever unable
to pay a judgment or other liability. Petitioner testified that
he worked for Ideal Management in 1992 for $400 a month, when his
services generated earnings of almost $6,000 a month. Petitioner
testified that he agreed initially to work for Ideal Management
for $300 per month, performing basically the services he
performed for almost 20 times that amount the year before.
Petitioner asks the Court to believe his testimony and hold for
him. We decline to do so. We find his testimony incredible.
See Ruark v. Commissioner, 449 F.2d 311, 312 (9th Cir. 1971),
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