Frank and Virginia Muhich - Page 6

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          sequence of transactions.  These materials touted the tax                   
          deductibility of all of the transferring individual's personal              
          expenses.  The materials generally claimed that the individual              
          would pay no tax on his or her income.  The materials made no               
          mention of any nontax benefit to be gained from the trust scheme.           
               After meeting with Myers, the Muhichs traveled over 100                
          miles to the offices of Heritage.  There they met with Edward               
          Bartoli (Bartoli), an attorney who was the  principal promoter of           
          Heritage's scheme.  Bartoli introduced petitioner to James Savino           
          (Savino), a certified public accountant associated with Heritage.           
          At or about the time of this meeting, the Muhichs submitted to              
          Heritage a form containing their financial information and                  
          assets.  On this form, they stated that their number one                    
          objective was "tax avoidance".                                              
          Creation of the Five Trusts                                                 
               In May 1994, very soon after meeting with Bartoli, the                 
          Muhichs, without consulting the Martins, implemented the multi-             
          trust scheme to avoid taxes.  Petitioner caused Midwest to pay              
          $12,000 to Heritage, and Heritage supplied petitioners with a               
          comprehensive packet of forms and documents that could be                   
          customized to create and operate the trust scheme.                          
          Petitioners used the promotional materials presented by Myers as            
          a model for their trust arrangement.                                        

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