Forest L. Buckmaster - Page 10

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                  (5)  foreign trusts in Belize acted as beneficiaries of the                            
            purchasers' trusts, and the foreign trusts owned the capital                                 
                  (6)  the purchaser was never the named capital unit holder;                            
                  (7)  each trust was established by a fictitious domestic                               
            trust, named "Cache Properties", for a nominal amount of $100;                               
                  (8)  the second trust was usually a foreign trust with a                               
            trustee named Dennis Smith;                                                                  
                  (9)  a purchaser could ensure perpetual control of his or                              
            her trust by naming himself or herself as secretary or manager;                              
                  (10)  a purchaser could not be removed or fired except with                            
            30 days' notice; and                                                                         
                  (11)  the trusts were "sold" by IBA for $2,500 apiece.                                 
            Following our detailed review of the facts surrounding Ideal                                 
            Management, with our knowledge of the facts in Scott, we reach                               
            the conclusion that Ideal Management was devised and operated                                
            similarly to the trusts examined in Scott.  We conclude that                                 
            Ideal Management, like the trusts in Scott, was a sham.  Accord                              
            Hanson v. Commissioner, 696 F.2d 1232 (9th Cir. 1983), affg. T.C.                            
            Memo. 1981-675; Markosian v. Commissioner, 73 T.C. 1235 (1980);                              
            Dahlstrom v. Commissioner, T.C. Memo. 1991-265, affd. without                                
            published opinion 999 F.2d 1579 (5th Cir. 1993); Dahlstrom v.                                
            Commissioner, T.C. Memo. 1991-264, affd. without published                                   
            opinion 999 F.2d 1579 (5th Cir. 1993).                                                       
                  Our conclusion is strengthened by our analysis of a number                             
            of factors that this Court has previously considered to help                                 

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