Gordon J. and Bonnie L. Schoof - Page 14

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          from the IRS office in Washington, D.C., dated March 27, 1987, to           
          act as a trustee for the FAC IRA trust.  This is the same date              
          reported by Mr. Thomson in FAC's IRA disclosure statement (given to         
          all prospective investors) in which he claims the IRA trust format          
          was approved by the IRS.                                                    
               Respondent produced a letter from his Washington, D.C., office         
          with the same serial No. (B111447b) and date (March 27, 1987) as            
          that reported by Mr. Thomson in his disclosure statement.  The              
          letter is addressed to "MFS Financial Service Inc" (MFS) of Boston,         
          Massachusetts, and states in part:                                          
               In our opinion, the amendment to the form of the                       
               prototype trust, custodial account or annuity contract                 
               identified above does not adversely affect its                         
               acceptability under section 408 of the Internal Revenue                
               Code.                                                                  
               Each individual who adopts this approved plan will be                  
               considered to have a retirement savings program that                   
               satisfies the requirements of Code section 408, provided               
               they follow the terms of the program and do not engage in              
               certain transactions specified in Code section 408(e).                 
               Please provide a copy of this letter to each person                    
               affected.                                                              
               The Commissioner's letter, despite Mr. Thomson's belief to the         
          contrary,  does  not  indicate  that  he  was  approved  by  the            
          Commissioner to serve as a trustee for the FAC IRA.  The letter             
          refers to an amendment to the form of a trust, see Rev. Proc. 87-           
          50, 1987-2 C.B. 647, 648, not to the approval of a trustee to serve         
          in that capacity.  Moreover, the letter was addressed to MFS of             







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