- 11 - transactions with the other trusts and Midwest.7 Throughout the 1995 year, petitioner moved funds among and between the Asset Trust, the Charitable Trust, and the Equity Trust in a circular fashion. Petitioner labeled the movements of funds "loans" or "loan repayments". For tax purposes, the Charitable Trust filed 1994 and 1995 returns claiming it was a nonexempt charitable trust under section 4947(a)(1), and it paid no tax for either year. The Equity Trust, the Business Trust, and the Vehicle Trust were dormant in 1994 and 1995, and each filed 1994 and 1995 income tax returns showing no taxable income. All of the above-described trust tax returns for 1994 were prepared by Savino. The Martins were not aware of petitioners' participation in the trust scheme until late 1994 when they prepared Midwest's tax return for that fiscal year. The Martins discovered that Midwest purportedly paid no wages to petitioner, 7 One such series of transactions occurred on June 21, 1995, when petitioner caused Midwest to pay the Asset Trust $14,247. On that same day, all of the following occurred: (1) The Asset trust paid $14,247 by check to the Charitable Trust; (2) the Charitable Trust paid $14,247 by check to the Equity Trust; and (3) the Equity Trust paid the $14,247 by check back to the Asset Trust. Also on June 21, 1995, petitioner repeated three more times this exact same series of movements of funds in a circular fashion in the exact same amount, $14,247. Petitioner labeled all of these advances "loans". Finally, petitioner caused the Asset Trust to pay back the $14,247 to Midwest by check dated June 21, 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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