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alia, a copy of an eight-page purported trust instrument dated
December 22, 1995 (purported trust instrument), a two-page
document entitled “The Adorno Business Company, Minutes of First
Meeting, December 22, 1995” (first minutes), and a notarized
affidavit dated October 17, 2002.
The purported trust instrument8 provides, in part, as
follows:
COMMON LAW BUSINESS ORGANIZATION
THIS COMMON LAW CONTRACT IN THE FORMAT OF AN IRREVOCABLE
DECLARATION OF TRUST AUTHORIZES ITS DIRECTORS TO OPERATE UNDER
THE NAME OF
The Adorno Business Company
(referred to as the company)
DATED December 22, 1995
THIS agreement, conveyance and acceptance is made
and entered into at the time and on the date appearing
in the acknowledgment hereto attached, by and between
The Adorno Asset Management Company CREATOR hereof and
INVESTOR herein, Edwin R. Adorno, Acceptor hereof in
fee simple as Director who shall comprise the Board of
Directors for conducting the business of The Adorno
Business Company hereby established.
THE CREATOR hereby constitutes and appoints the
above designated Director to be, in fact, Director of
The Adorno Business Company hereby created and
established. THE CREATOR for and in consideration of
the objects and purposes herein set forth and other
considerations of value the receipt of which is hereby
7(...continued)
other relevant times, Mr. Adorno claimed to be the director,
fiduciary, legal representative, or executive director of Adorno
Business.
8 The provisions of the purported trust instrument are
substantially identical to the purported trust instrument in The
Adorno Asset Mgmt. Trust v. Commissioner, T.C. Memo. 2003-127.
See infra note 12.
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