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FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioners Steve M. Norton (Mr.
Norton) and Khristine Norton (Mrs. Norton), husband and wife,
resided in Palmer, Alaska, at the time they filed their
petitions. Petitioners South Denali Lands Trust and Denali
Company Trust had mailing addresses in Palmer, Alaska, at the
time of the filing of the petitions.
Mr. Norton is a general contractor in the construction
business. He operated a sole proprietorship under the name of
Steve Norton Enterprises (SNE). In 1973, he moved to Alaska from
Oregon. In the early 1980s, Mr. Norton purchased residential
real estate in Alaska for income and investment purposes. Due to
a downturn in the State’s economy, his rental units became
vacant, the value of his real estate sharply decreased, and Mr.
Norton could not find any contract work. As a result, almost all
of the real estate that Mr. Norton owned was foreclosed upon,
and, in 1987, Mr. and Mrs. Norton filed a bankruptcy petition.
In 1993, Mr. Norton went to a presentation at his church by
Lonnie Crockett (Mr. Crockett) concerning trust2 programs. Mr.
Norton attempted to consult his attorney about the trust
2 For convenience, we use the terms “trust” and “trustee”.
The use of such terms is not intended to be conclusive as to
characterization for tax purposes.
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Last modified: May 25, 2011