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The 1994 trust instrument provides, in pertinent part, as
follows:
[Begin unnumbered cover page]
* * * * * * *
THIS DOCUMENT IS CREATED UNDER COMMON LAW
RIGHT OF CONTRACT IN WASHINGTON D.C.
RESIDENTIAL MANAGEMENT SERVICES[7]
A Trust Organization and/or Pure Trust executed Under
The Constitutional Laws of the United States of America
Dated: MAY 24, 1994
[End unnumbered cover page]
DECLARATION OF IRREVOCABLE TRUST
This Declaration of Irrevocable Trust is created this
24TH DAY OF MAY 1994, between CONTRACT ADMINISTRATORS
TRUST, of Washington, D.C., hereinafter called the
SETTLOR and AMERICAN COMMON TRUST, Washington, D.C.,
with mailing address of Tempe, Arizona, Douglas J.
Carpa, Trust Officer, hereinafter called the TRUSTEE,
who are legal entities holding full title, not as
individuals, but collectively as the Board under the
name of RESIDENTIAL MANAGEMENT SERVICES * * *.
6(...continued)
was not a proper person authorized to petition the Court on
behalf of the “trust”. See Rancho Residential Facility Trust v.
Commissioner, docket No. 9120-00; Residential Mgmt. Servs. Trust
v. Commissioner, docket No. 9119-00 (involving the 1996 tax
year); Home Health Servs. Trust v. Commissioner, docket No. 9118-
00; Sunshine Trust v. Commissioner, docket No. 9117-00;
Residential Mgmt. Servs. Trust v. Commissioner, T.C. Memo. 2001-
297 (involving the 1995 tax year); cases cited supra n.2.
7 The record indicates that Residential Management Services
and Residential Management Services Trust are one and the same.
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