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1. Petitioner’s Residential Facilities
In 1997, petitioner worked with severely disabled adults at
Residential Management Services, Rancho Residential Facility,
Sunshine Residential Facility, and Home Health Services, which
are residential facilities for disabled adults.
2. The Trusts
Petitioners formed Residential Management Services Trust1
(Residential), Rancho Residential Trust (Rancho), Sunshine
Residential Trust (Sunshine), and Home Health Services Trust
(Home Health) (petitioners’ trusts) before 1997.2 Petitioners’
trusts purportedly were in the business of operating nursing and
personal care facilities in 1997. Petitioners’ four children
have been the sole named beneficiaries of petitioners’ trusts
since 1997. Robert Hogue (Hogue) was the purported trustee of
these trusts in 1997. He was paid no more than $500 per trust in
1997 for his services as trustee.
Bank accounts were maintained for petitioners’ trusts.
Petitioner had signature authority over those accounts in 1996
and part of 1997. He paid his personal expenses from those bank
1 Our use of the words "trust”, "trustee”, and "form” does
not necessarily indicate that we believe the transactions at
issue have substance.
2 Petitioners formed Home Health Services Trust on June 1,
1993, Residential Management Services Trust on Dec. 16, 1994, and
Rancho Residential Trust and Sunshine Residential Trust on Aug.
1, 1996.
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Last modified: May 25, 2011