Allen O. Zachman and Bernadette Zachman - Page 10




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         disbursements included $125 per month to Joan Noske for her                  
         bookkeeping services.                                                        
              On November 16, 1985, the U.S. District Court for the                   
         District of Minnesota entered a Final Judgment of Permanent                  
         Injunction as to James and Joan Noske, finding that they had                 
         engaged in conduct subject to penalty under section 6700 and                 
         enjoining them from organizing, assisting, selling, or otherwise             
         promoting business trusts as abusive tax shelters.  As part of               
         the judgment, the Noskes were ordered to supply respondent’s                 
         District Director with the names and addresses of all purchasers             
         of the 186 business trusts on file with the Minnesota Secretary              
         of State which list Armageddon and Parnell as corporate trustees.            
         Subsequently, the Noskes identified Oak Hill and Pleasant Acres              
         as being among the business trusts involved in the injunction                
         action.                                                                      
              In September 1995, Joan and James Noske were convicted of,              
         among other things, conspiracy to defraud the United States by               
         impeding the Internal Revenue Service, and conspiracy to evade               
         Federal income taxes.  The convictions were based on the Noskes’             
         participation in a scheme to assist their clients in reducing or             
         avoiding Federal income taxes by forming business trusts which               
         named Armageddon and Parnell as trustees.  It was further                    
         determined that the Noskes participated in a scheme whereby their            
         clients would transfer all of their income-producing property to             





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