Frank and Virginia Muhich - Page 8




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          representing 100 units of ownership in the Charitable Trust.                
          The Muhichs were the trustees.                                              
               On May 15, 1994, the Asset Trust created The Muhich Business           
          Trust (Business Trust).  The Asset Trust funded the corpus with             
          $10 in exchange for a CBI representing 100 units of ownership in            
          the Business Trust.  The Muhichs were the trustees.                         
               On May 18, 1994, the Business Trust established The Muhich             
          Equity Trust (Equity Trust) and The Muhich Vehicle Trust (Vehicle           
          Trust).  The Business Trust funded the corpus of each trust with            
          $10 in exchange for a CBI from each trust representing 100 units            
          of ownership in each.  The Muhichs were the trustees.                       
               The Muhichs listed their personal residence at 1106 West               
          Dianne as the address for the five trusts.  As sole trustees and            
          exclusive beneficiaries of all five trusts, the Muhichs had                 
          exclusive control over the trust property.  They had the right to           
          receive distributions at their sole discretion and controlled all           
          the bank accounts.  Their ability to deal with and benefit from             
          all trust property was as free and unrestricted as before the               
          trusts were established.                                                    
               Midwest continued to operate as a corporation and continued            
          to conduct business the same as before the trusts were created.             
          Petitioner's work and duties at Midwest remained the same, but he           
          no longer took a salary from Midwest.  Instead, he caused Midwest           
          to contract with the Asset Trust for the provision of his                   





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