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The Courts generally will not recognize a trust for Federal
tax purposes if the grantor keeps substantially unfettered powers
of disposition or beneficial enjoyment of trust property. See
United States v. Noske, 117 F.3d 1053, 1059 (8th Cir. 1997);
Paulson v. Commissioner, 992 F.2d 789, 790 (8th Cir. 1993), affg.
per curiam T.C. Memo. 1991-508; United States v. Buttorff, 761
F.2d 1056, 1061 (5th Cir. 1985); Schulz v. Commissioner, 686 F.2d
490, 495 (7th Cir. 1982), affg. T.C. Memo. 1980-568; Vnuk v.
Commissioner, 621 F.2d 1318, 1320-1321 (8th Cir. 1980), affg.
T.C. Memo. 1979-164. Petitioner dealt with the alleged trust
property as if it were his own. He continued to live in the
Scottsdale residence. He did not change how he conducted his
medical practice. He controlled Arivada’s checking account, kept
the checkbook, and wrote the checks on the account. There is no
evidence that Chisum wrote or signed any checks on the account.
Petitioner contends that Chisum controlled Arivada and
managed the financial aspects of petitioner’s medical practice
during the years in issue. We disagree. Petitioner’s and
Chisum’s testimony was evasive and vague. We need not accept
self-serving testimony if we find it to be unworthy of belief,
Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971),
affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). Petitioner offered no documentary
evidence showing that Chisum provided services to Arivada.
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