Forest L. Buckmaster - Page 9

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            affg. per curiam T.C. Memo. 1969-48; Clark v. Commissioner, 266                              
            F.2d 698, 708-709 (9th Cir. 1959), affg. in part and remanding in                            
            part T.C. Memo. 1957-129; Tokarski v. Commissioner, 87 T.C. 74,                              
            77 (1986); see also Hawkins v. Commissioner, T.C. Memo. 1993-517,                            
            affd. without published opinion 66 F.3d 325 (6th Cir. 1995).                                 
                  The Court of Appeals' opinion in United States v. Scott,                               
            supra, is most helpful to us in understanding the form,                                      
            substance, and operation of Ideal Management.  The opinion                                   
            describes in detail how the trusts were marketed as a device for                             
            a purchaser to eliminate his or her income tax liability without                             
            losing control of his or her money and other assets.  Like the                               
            trust at hand, the trusts in Scott were generally structured so                              
            that it would appear that the trust income was distributed to                                
            foreign trust beneficiaries, which then redistributed the income                             
            to other foreign trust beneficiaries that were outside the reach                             
            of the U.S. taxing arm.  Id. at 1570.  Other relevant                                        
            characteristics of the trusts examined in United States v. Scott,                            
            supra, include that:                                                                         
                  (1)  The purchasers transferred their property, including                              
            houses, into trust;                                                                          
                  (2)  the trusts claimed depreciation deductions for the                                
                  (3)  the trusts were reported to the Commissioner as simple                            
                  (4)  Mr. Yung was a trustee;                                                           

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