Allen O. Zachman and Bernadette Zachman - Page 9




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         operation, including the parts business, were sent to Joan Noske             
         at a post office box in Cold Springs, Minnesota.  Some of these              
         amounts were received at this post office box directly from the              
         payors.  In other instances, payors sent checks directly to                  
         petitioners, who would forward them to the Cold Springs post                 
         office box.  When petitioners received bills from companies they             
         bought parts from, these too were generally forwarded to the Cold            
         Springs post office box.                                                     
              Joan Noske generally made provision out of “Oak Hill” funds             
         for paying farm expenses, parts inventory purchases, utility and             
         other billings, and real estate taxes, as well as for paying                 
         certain of petitioners’ living expenses, including expenses for              
         insurance, reroofing petitioners’ personal residence, hospital               
         bills, a newspaper subscription, and property taxes on                       
         petitioners’ residence.  Oak Hill also paid 40 percent of                    
         petitioners’ utilities.                                                      
              During the years at issue, Joan Noske did all the                       
         bookkeeping for Oak Hill.  She prepared the Federal income tax               
         returns for Oak Hill and at least 20 other trusts that name                  
         Armageddon and Parnell as trustees.  She also prepared                       
         petitioners’ income tax returns for the years in issue.  On a                
         monthly or bimonthly basis, petitioners received ledgers from                
         Joan Noske which accounted for funds purportedly received and                
         disbursed by Oak Hill during the years at issue.  The                        





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