- 8 -
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”.
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