- 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