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Amaranth Holding Trust (Amaranth) held the 100 certificates
of interest issued by United Sovereigns. In 1989, petitioners
formed Amaranth. Amaranth issued 100 certificates of interest--
50 to Mr. Christal and 50 to Mrs. Christal. Petitioners
continued to hold the Amaranth certificates up to and through
1992. Thus, petitioners, through Amaranth, were the ultimate
beneficiaries of United Sovereigns.
Mr. Christal had the power to distribute the principal or
income of United Sovereigns to Amaranth or to convert the trust
property into cash and distribute it to its certificate holders
for their support, care, maintenance, education, medical
expenses, or emergencies. Additionally, United Sovereigns could
only be terminated with the approval of its current
beneficiaries.
United Sovereigns promoted the principles of network
marketing and offered services and activities to customers
including, but not limited to, a monthly newsletter, tax
services, and estate planning. Customers of United Sovereigns
paid $50 a month to receive these services. The customers could
have the monthly fee withdrawn automatically from their bank
account by EFTS which would transmit the payment to United
Sovereigns. In 1992, United Sovereigns reported total income of
$144,976 on its Form 1041.
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Last modified: May 25, 2011