- 5 - STL’s place of business. Mr. Sowards went to his STL office on a regular basis. Mr. Sowards, STL, and Mr. Strong had a close business relationship.4 Mr. Sowards, Mr. Strong, and STL referred clients among themselves. Mr. Sowards performed legal services for STL and advised many of STL’s clients.5 Mr. Sowards traveled and assisted Mr. Strong with seminars promoting STL’s services conducted in Ohio, Hawaii,6 Alaska, and Texas. STL reimbursed Mr. Sowards for business and travel expenses. STL also provided Mr. Sowards with an American Express credit card. On or about June 1, 1994, Mr. Sowards, with the assistance of Mr. Strong, purportedly created an intervivos trust named Wealth Preservation Assistance (WPA). Mr. Sowards was the sole grantor of WPA.7 The trust document states that WPA’s business purpose is “diversification of business activities and business assets for planned constructive growth.” 4Petitioner Marilyn Sowards (Ms. Sowards) testified that Mr. Strong and her husband had a contract relationship. 5Mr. Sowards testified that he performed these legal services as a courtesy and on a pro bono basis. 6In one of the years at issue, Mr. Sowards traveled to Hawaii as many as nine times to assist Mr. Strong with the STL seminars. 7Mr. Sowards testified that there were three main reasons for establishing WPA: (1) For use in doing charitable, pro bono legal work; (2) for use on some minor business transactions; and (3) for use in estate planning. WPA was never used for charitable purposes or as a business entity.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011