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Oxyfresh business as a regular corporation, an S corporation, or
a business trust. In 1989 or 1990, Mr. Fox met Larry Smith
(Smith) who recommended that Mr. Fox not incorporate his Oxyfresh
business. The record does not describe Smith's professional
qualifications.
In June 1991, Mr. and Mrs. Fox decided to form a business
trust.2 Smith formed an entity called Prindle International
Marketing (Prindle) for Mr. and Mrs. Fox in California, on June
21, 1991.
On July 1, 1991, Smith wrote several documents in
Sacramento, California, which purported to make Prindle a
business trust of which Mr. and Mrs. Fox were the beneficiaries.
Smith signed the documents as creator.
On July 10, 1991, the U.S. Treasury Department issued an
employer identification number to Prindle.
On January 2, 1992, Mr. and Mrs. Fox opened a checking
account under the name Prindle International Marketing (Prindle
account). They were the only persons authorized to sign checks
on the Prindle account.
2 We use the words "business trust", "trust", "trust
documents", "trustee", "grantor", "transferor", "form",
"establish", and "agent", in our findings of fact for narrative
convenience. We do not intend our use of those terms to indicate
any conclusion about the substance of the transactions at issue.
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