Leon L. Zachman and Estate of Ione Zachman - Page 9

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         problems.  During the years at issue, his work on the farm                   
         consisted largely of riding a tractor or baling hay no more than             
         a few times a week.  Ione Zachman did not participate in the farm            
         work, apart from growing her own garden.  Both before and after              
         the creation of Hillside Farm, petitioners’ sons, Dale and Paul,             
         performed most of the farm work.  Dale made most of the farming              
         decisions.  Dale and Paul each received weekly wages for their               
              All the gross receipts from petitioners’ farming operation              
         were sent to Joan Noske at a post office box in Cold Springs,                
         Minnesota.  Joan Noske generally made provision out of “Hillside             
         Farm” funds for paying farm expenses, as well as certain of                  
         petitioners’ personal expenses, including insurance, medical                 
         bills, income taxes, and property taxes on petitioners’                      
              During the years at issue, Joan Noske did all the                       
         bookkeeping for Hillside Farm.  She prepared the Federal income              
         tax returns for Hillside Farm and at least 20 other trusts that              
         name Armageddon and Parnell as trustees.  She also prepared                  
         petitioners’ Federal income tax returns for the years in issue.              
         At least twice a year, petitioners received ledgers from Joan                
         Noske which accounted for funds purportedly received and                     
         disbursed by Hillside Farm during the years at issue.  The                   

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Last modified: May 25, 2011