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Facts Concerning Petitioner’s Connection With Universal
On June 15, 1990, Donna L. Chisum as “Settlor”, Four WS TT01
as “First Trustee”, and Mr. Chisum and another individual as
“Witness[es]”, executed a document (the indenture)4 purporting to
create an entity known as “Universal Trust”. The indenture
stated that Universal was a “COMMON LAW BUSINESS TRUST
ORGANIZATION, also known as a CONTRACTUAL COMPANY * * * with
certain assets to be administered by the Trustee for capital Unit
Holders represented by Certificates in accordance with the
inalienable Common Law rights afforded to man.” Notwithstanding
this language purporting to create a trust, the indenture also
stated that “It is expressly declared that an Unincorporated
Business Organization by Contract is hereby created and not a
trust agreement by gift, or a partnership, or a company, or a
corporation, or a joint venture, or any entity of statutory
nature”. (Emphasis added.)
Other documents dated June 15, 1990, show that all 100
“capital units” that could be issued by Universal were issued on
that date to petitioner and Ms. Ghavami. These documents state
that the capital units were issued in exchange for petitioner’s
and Ms. Ghavami’s contribution to Universal of the following:
4 We use the term “indenture” for convenience and not to
suggest that Universal should be recognized as a trust for State
law or Federal income tax purposes.
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Last modified: May 25, 2011