Kevin R. Johnston - Page 10




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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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Last modified: May 25, 2011