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keep the farm together in the family.” It is unclear, however,
how the establishment of Oak Hill would accomplish any such
objective. Under Article III, Section 8 of the Declaration of
Trust, if any trust certificate holder dies before termination of
the trust, his shares become “null and void and shall immediately
revert to the Board of Trustees, who shall thereupon name a
replacement beneficiary or beneficiaries”. Accordingly, the
creation of Oak Hill would have provided petitioners no assurance
that the farm would remain in their family. To the contrary,
under the terms of the Declaration of Trust, absolute power over
the disposition of the farm property, either during their lives
or upon the death of either petitioner, would have resided with
Parnell and Armageddon. In any event, the expectancy of an
estate-planning advantage does not establish entitlement to an
income tax advantage. See Prindle Intl. Marketing, UBO v.
Commissioner, T.C. Memo. 1998-164.
Similarly, petitioners argue that the establishment of Oak
Hill was motivated by a desire to achieve limited liability with
respect to the parts business, in order to protect the farm
property. We conclude, however, that any such objective was
peripheral to petitioners’ primary objective of deflecting their
taxable income. Petitioners’ personal farm property was
commingled with the parts business property in Oak Hill, and so
was not insulated from liability arising from the parts business.
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