Christa Karin Mueller - Page 11




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          probation.  The sentencing judge provided that husband could                
          reduce the length of his sentence by making restitution.  The               
          sentencing judge rejected husband’s claim of indigence:  “[T]he             
          court feels confident that you have either secreted funds or you            
          have placed funds in trust to other family members so that funds            
          are available.”                                                             
          Christa Karin Mueller Trust                                                 
               The Christa Karin Mueller Trust (the trust) was established            
          by agreement dated April 30, 1989, between petitioner, as                   
          grantor, and husband’s brothers, as trustees.  Petitioner is the            
          sole vested beneficiary under the trust.  The trust is governed             
          by the laws of Germany.                                                     
               The trust was funded with stocks and bonds with a cost basis           
          of $1,057,852.09 and an approximate fair market value at the time           
          of transfer of $1,150,509.  The stocks and bonds were transferred           
          from accounts with Prudential-Bache and Shearson Lehman Hutton              
          Inc., held in petitioner’s name alone.  The trust funds are                 
          managed by Dresdner Bank located in Luxembourg.                             
               Petitioner received at least one distribution from the trust           
          in the amount of $13,700 in 1990, and approximately $100,000 in             
          distributions in 1991 through 1993.  On or about July 12, 1994,             
          petitioner obtained $450,000 by wire from the trust, which funds            
          were used to post cash bail (the cash bail) for husband in the              
          case leading to the 1994 conviction.                                        






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