Orneal and Martha Kooyers, et al. - Page 8

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               Mrs. Kooyers transferred to Mr. Kooyers all of her interest            
          in all her real and personal property.6  Mr. Kooyers then                   
          transferred all of petitioners’ property, real and personal, to             
          the OMK Family Trust.  The declaration of trust of the OMK Family           
          Trust states that the trustees were authorized to accept rights,            
          title, and interest in real and personal property conveyed by Mr.           
          Kooyers to be the corpus of the trust, including “the exclusive             
          use of his lifetime services and ALL of his EARNED REMUNERATION             
          ACCRUING THEREFROM”.                                                        
               For 1998, the OMK Company Trust entered into separate                  
          agreements with P.I. Ministries, pursuant to which the trust                
          agreed to provide the services of petitioners as independent                
          contractors to P.I. Ministries and P.I. Ministries agreed to pay            
          the trust for services provided by petitioners.  Mr. Kooyers was            
          to serve as assistant to P.I. Ministries’ chief executive                   
          officer, and Mrs. Kooyers was to serve as a missionary.  In 1998,           
          P.I. Ministries paid the OMK Company Trust $106,788 for                     
          petitioners’ services.                                                      
               In 1998, the OMK Company Trust paid all expenses petitioners           
          thought were related to their mission work, including the costs             
          of their housing, medical care, travel, and family gatherings.              



               6The property Mrs. Kooyers conveyed to Mr. Kooyers included            
          exclusive use of her lifetime services “exception being that of             
          an employee situation”.                                                     





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