- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011