Adorno Business Company - Page 8

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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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