Kevin D. Castro and Margarita C. Castro, et al. - Page 7




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               (5) On May 5, 1994, the Castros, as trustees of the CFT,               
          executed a bill of sale purporting to sell the assets of the                
          jewelry business to the CCJT for $10 and other consideration.               
               B.  The Operation of the Trusts                                        
               The declarations of trust with respect to the CFT and the              
          CCJT provided in pertinent part as follows:                                 
               1.  The CFT                                                            
               The CFT’s declaration of trust described the function and              
          purpose of the CFT:                                                         
               THE TRUSTEES purpose shall be authorized to accept                     
               rights, title and interest in and to real and personal                 
               properties, whether tangible or intangible, which have                 
               been conveyed by THE CREATOR HEREOF AND GRANTOR HERETO                 
               to be the CORPUS OF THIS TRUST.  Included therein is                   
               the exclusive use of HIS lifetime services and ALL of                  
               HIS EARNED REMUNERATION ACCRUING THEREFROM, from any                   
               current source whatsoever, so that Kevin D. Castro can                 
               maximize HIS lifetime efforts through the utilization                  
               of HIS Constitutional Rights; for the protection of HIS                
               family in the pursuit of HIS happiness through HIS                     
               desire to promote the general welfare, all of which                    
               Kevin D. Castro feels HE will achieve because they are                 
               sustained by HIS RELIGIOUS BELIEFS.                                    
               The declaration of trust divided the beneficial interests in           
          the trust into 100 units in certificate form.  The units were               
          “non-assessable, non-taxable * * *, non-negotiable, non-                    
          transferable (except back to THE TRUST)”.  The declaration of               
          trust prohibited the trustees from issuing more than the initial            
          100 units of beneficial interest.  In consideration for                     
          petitioner’s contribution of assets and his promise to render               







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