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Simultaneously, petitioners purportedly conveyed to Pleasant
Acres three life insurance policies and an extensive assortment
of personal property, including furniture, china, lamps, home
appliances, and an encyclopedia.
Oak Hill and Pleasant Acres both purport to be business
trusts formed pursuant to Minnesota law. The named trustees of
each of these purported trusts are Parnell, Inc. (Parnell) and
Armageddon, Inc. (Armageddon), nonprofit corporations organized
under the laws of South Dakota. These corporations are also the
named trustees for numerous other business trusts.
The Declaration of Trust of Oak Hill (Declaration of Trust),
dated April 25, 1983, recites that it is made between Parnell and
Armageddon, “herein referred to as Trustees, for the purpose of
enabling the Trustees to hold and manage the trust estate and to
carry on business as hereinafter provided.” The Declaration of
Trust further provides in pertinent part:
ARTICLE III. SHARES
SECTION 1. The beneficial interest in this trust shall
be divided into shares without par value. Upon unanimous
approval of the Board of Trustees, shares may be sold or
exchanged for such consideration, and on such terms, as the
Trustees deem proper. All shares shall be evidenced by
trust certificates of which [sic] shall be signed by each of
the Trustees.
SECTION 2. The certificates shall entitle owners
thereof to participate proportionately in all dividends and
other distributions of income or principal as the Trustees
may, from time to time, in their absolute discretion,
declare and pay out; provided that, upon the termination of
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