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in Arizona on May 25, 1994. In its entirety, the document that
was filed with the Maricopa County Recorder on that date
consisted of only a one-page unnumbered cover sheet that is
identical to the cover sheet of both the 1994 trust instrument
and the altered trust instrument.
Robert Hogue appeared pro se, purportedly on behalf of
Residential Management. The only evidence he offered was his
naked assertion that he is entitled to appear on behalf of
Residential Management because he was appointed trustee on July
15, 1997.
G. Post-Hearing Memorandum Briefs
A memorandum brief, which was signed by Robert Hogue, does
nothing more than repeat the same unsubstantiated and conclusory
allegations made in the petition and in the objection; i.e., that
Robert Hogue is the trustee for Residential Management.
In an answering memorandum brief, respondent contends that
the facts of this case are substantially identical to the facts
in Residential Mgmt. Servs. Trust v. Commissioner, T.C. Memo.
2001-297, holding that Robert Hogue was not properly appointed as
trustee, and that Robert Hogue did not have authority to alter
the 1994 trust instrument.
Discussion
According to respondent, Residential Management failed to
show that Robert Hogue is its duly appointed trustee. Respondent
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Last modified: May 25, 2011