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Desk, chair, file cabinet, typewriter,
wastebaskets (2) telephones, VCR & TV, bedroom
furnishings, living room furniture dining room set,
coffee tables, end tables, pictures, etc. note owed to
Lynne B. Johnston for $3500.00 knowledge, talent,
ability and labor of [petitioner] * * * office supplies
and office tools[.] [Emphasis added.]
The indenture provided that whenever the “board of trustees”
determined that Universal had income that would be taxable to
Universal if not distributed, the income was to be distributed to
capital unit holders in proportion to their holdings; any
remaining income was to be allocated to principal. The indenture
also provided that on termination of Universal any remaining
assets would be distributed to capital unit holders, also in
proportion to their holdings.
Other documents dated June 15, 1990 named petitioner
“Secretary” and Ms. Ghavami “General Manager” of Universal, and
gave them authority to conduct Universal’s day-to-day business.
As noted above, both petitioner and Ms. Ghavami could and did
sign checks on Universal’s bank account.
A document entitled “Registry of Unit Certificates” purports
to show that in December 1990, the 100 capital units in Universal
were transferred to an entity known as “Isiah 18", and that in
October 1991, they were transferred to an entity known as “Oak
Harbor”. Mr. Chisum testified that Oak Harbor was a trust
established in the Turks and Caicos with a foreign trustee; he
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