Robert M. Temple - Page 13




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               On January 25, 1988, Black Creek Management Co. with Nassau            
          Life Insurance Co., Ltd., as trustee granted by warranty deed for           
          a stated consideration of $1 the 5501 and 5955 properties to                
          Trundle Management with Eton Trust Co., Ltd., as trustee22 by               
          warranty deed.23  On the same day, Old Labrador Investment Co.              
          with Nassau Life Insurance Co., Ltd., as trustee, granted for $1            
          in consideration its royalty interest in the oil and gas leases             
          in both properties to Trundle Management with Eton Trust Co.,               
          Ltd., as trustee.                                                           
               Petitioner and his wife continued to reside at the 5955                
          property.  Petitioner continued to use the 5501 and 5955                    
          properties for livestock operations and to operate a veterinary             
          clinic.  Petitioner continued to exercise dominion and control              
          over the 5501 and 5955 properties.                                          
               Pennzoil Oil and Scavenger Oil paid royalties for use of the           
          oil and gas wells located on both properties during the years in            


               22The tax mailing address used by Eton Trust Co., Ltd., on             
          the warranty deeds was Grant Petroleum Building, Providenciales,            
          British West Indies.                                                        
               23The timing of the transfer is similar to the facts in                
          Bodor v. Commissioner, supra.  The taxpayer in that case was                
          Frank R. Bodor.  He is the attorney representing petitioner in              
          the present case.  In Bodor, we found that the taxpayer                     
          transferred his interest in eight properties by quitclaim to                
          various foreign entities for which Nassau Life Insurance Co.                
          served as trustee, that due to illegal activities in late 1986 or           
          early 1987, Nassau Life ceased operations, and that Mr. Bodor               
          knew that the problems stemmed from illegal activities and a “tax           
          situation”.                                                                 





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