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real and personal property, including the Castros’ home and
furnishings, in exchange for $20 and other consideration.
(2) On April 8, 1994, petitioner, as grantor, executed a
declaration of trust prepared by Dependable Services Group (DSG)
entitled “Castro Family Trust”. In the declaration of trust,
petitioner promised to provide lifetime services and to transfer
any remuneration paid for those services to the trust. Part of
the consideration petitioner purportedly received in exchange for
his transfer of assets to the CFT and his promise to provide
lifetime services and any resulting remuneration exclusively for
the benefit of the CFT consisted of all 100 units of beneficial
interest in the CFT.
(3) On April 8, 1994, petitioner executed a bill of sale
and a quitclaim deed, which recited that petitioner conveyed all
of his interest in real and personal property, including his home
and furnishings, to the CFT in exchange for $20 and other
consideration.
(4) On May 5, 1994, the CFT, as grantor, executed a
declaration of trust prepared by DSG entitled “Castro & Co.
Jewelers”. The declaration of trust recited that the CFT had
transferred the assets of the jewelry business to the CCJT in
exchange for $10 and all 100 units of beneficial interest in the
CCJT.
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