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Leon and Ione Zachman were married until her death in 1989.
Leon Zachman is the representative of the Estate of Ione Zachman.
Unless otherwise indicated, “petitioner” hereinafter refers to
Leon Zachman, and “petitioners” refers to Leon Zachman and Ione
Zachman. Petitioner resided in Rogers, Minnesota, when the
petition was filed.
Petitioners have farmed in the Rogers area since 1949.
Prior to 1983, petitioners’ farm was held in Shady Elms Farm, a
trust promoted by Lowell Anderson.2 On January 26, 1983,
petitioners transferred their farm real property to another
trust, Walnut Leaf. In 1983, petitioner attended a meeting with
other farmers to hear a presentation by James Noske and Norb
Stelton about utilizing business trusts. On September 8, 1983,
petitioners executed bills of sale, purporting to transfer their
farm equipment and livestock to Hillside Farm. On the same date,
in their capacities as trustees of Walnut Leaf, petitioners
deeded their interests in the farm real property to Maplewood Co.
(Maplewood). On October 4, 1983, petitioners executed a bill of
sale whereby for the stated consideration of “One dollar and
other good and valuable consideration” they transferred to
2 On Feb. 24, 1983, Lowell Anderson was indicted by a
Federal grand jury in Wyoming for conspiring to defraud the
United States by selling common-law trusts which were used to
evade Federal income taxes. See United States v. Tranakos, 911
F.2d 1422, 1424 (10th Cir. 1990). Lowell Anderson died while the
criminal proceedings were pending. See id.
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