Frank and Virginia Muhich - Page 17

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          petitioners dealt freely with trust funds and property, and they            
          manipulated funds between the trusts in a circular and                      
          nonsensical manner.  This factor weighs against petitioners.                
               In addition to our analysis of the Markosian factors, all of           
          which favor respondent, other facts herein make clear that the              
          tangled web woven by petitioners did little more than conceal the           
          ownership of assets and disguise the true earner of income for              
          the purpose of avoiding taxes.  First, petitioners created an               
          elaborate scheme of documents and paperwork with an eye towards             
          creating an aura of legitimacy for the trusts.  These canned                
          documents were part of the mass-produced trust package marketed             
          by Heritage and paid for with the $12,000 fee.  Notwithstanding             
          the Muhichs spent time filling in the blanks, these documents do            
          not lend economic reality to the transactions they purport to               
          memorialize, and we place no weight on them.                                
               Second, petitioner lacked a basic understanding of the                 
          scheme's operation.  He was generally unfamiliar with the                   
          intricacies and interworkings of the trust scheme, and he was               
          unfamiliar with basic terms such as "grantor", "beneficiary", and           
          "trust declarations".  Instead of directly responding to                    
          questions asked at trial, petitioner often referred the Court to            
          the reams of paperwork submitted into the record with the                   
          suggestion that the answers could be found somewhere in those               

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