Allen O. Zachman and Bernadette Zachman - Page 7




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         petitioners or heard of Oak Hill.  Neither ever managed Oak Hill.            
         They each signed various papers, including blank or incomplete               
         pages, at the request of James or Joan Noske.  Foshaug often                 
         neither read nor understood the pieces of paper she signed.  As              
         president of Parnell, Inman took no action other than as directed            
         by James or Joan Noske.3                                                     
              The minutes for the Oak Hill trustees’ meeting dated                    
         September 14, 1983, signed by Foshaug and Inman, indicate that               
         the trustees appointed Daniel Strohmeier as manager of Oak Hill,             
         with authority to oversee the business operations of the trust               
         and to issue checks to pay general operating expenses.4  If                  
         Strohmeier ever conducted business related to Oak Hill, it was at            
         the direction and under the control of James or Joan Noske.                  
              Sometime in 1987 or 1988, John B. Ellering became president             
         of Armageddon and Parnell, and replaced Strohmeier as                        


               3 On June 14, 1985, the U.S. District Court for the District           
          of Minnesota entered a final judgment of permanent injunction as            
          to Foshaug, Inman, Armageddon, and Parnell, enjoining them under            
          secs. 7408 and 7402 from organizing or assisting in the                     
          organization of an abusive tax shelter plan or arrangement                  
          involving business trusts.                                                  

               4 Another case involving Noske trusts, Scherping v.                    
          Commissioner, T.C. Memo. 1989-678, includes as a finding of fact            
          that in June 1983 James and Joan Noske took Strohmeier from an              
          alcoholic treatment center, made him a figurehead president of an           
          entity to which the taxpayers had transferred their dairy farm              
          assets, and placed him on the taxpayers’ family farm to live and            
          work for the last half of 1983, doing farm chores at the                    
          taxpayers’ direction.                                                       





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