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On November 10, 1993, Jones-George deeded to petitioner her
one-half community property interest in the Scottsdale residence.
On November 27, 1993, petitioner deeded the Scottsdale residence
to Stepping Stone. Petitioner received 100 capital units in
trust property for the residence.
Petitioner lived in the Scottsdale residence with Jones-
George until she moved out late in 1993. Petitioner lived in the
Scottsdale residence until it was sold after the years in issue.
He paid the monthly mortgage on the residence both before and
after he transferred the residence to Stepping Stone. He did not
pay rent to, or have a lease or rental agreement with, Stepping
Stone for the use of the residence. He did not use the
Scottsdale residence differently after he transferred it to
Stepping Stone.
C. Arivada Health Enterprises Trust
1. Formation of Arivada
Petitioner and Chisum met several times in 1992 and 1993.
Chisum gave petitioner information about forming and using
trusts. Arivada was formed on June 26, 1993. Chisum signed
documents naming him trustee of Arivada beginning in 1993.
Chisum was not an osteopathic or homeopathic physician.
Petitioner did not consult an accountant or attorney to
discuss the validity of the trust before he entered into the
trust agreement. Jones-George did not participate in the trust
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