Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 18

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          each other in the course of signing the documents to establish              
          the McKenzie Trust.                                                         
               On May 14, 1993, Mr. Hartmann and Mr. Boatright executed a             
          contract entitled “McKenzie Trust, A Contractual Fiduciary                  
          Trust”.  The contract contained a declaration of trust and trust            
          indenture, the terms of which were identical to the Pago Trust’s            
          formation documents.  Although Mr. Boatright never issued                   
          certificates representing the 100 units of beneficial interest in           
          the McKenzie Trust, the parties stipulated that Glenmere                    
          Investments was the 100-percent beneficiary of the trust during             
          the taxable years 1995 through 1998.20  Glenmere Investments and            
          its fiduciary are located in Nevis, British West Indies.                    
               B.   Operation of the McKenzie Trust                                   
               On May 14, 1993, the McKenzie Trust and petitioner executed            
          a General Agreement in which petitioner agreed to manage the                
          McKenzie Trust.  The terms of the agreement were vague, requiring           
          only that petitioner perform “duties as the manager of the                  
          McKenzie Trust and make sound business decisions which affect the           
          function and operation of the said trust as a whole.”  The trust            
          paid petitioner management fees for his services.                           




               20The McKenzie Trust’s tax returns for 1995 and 1997 have              
          Schedules K-1 that list Glenmere Investments as a beneficiary,              
          but there are no Schedules K-1 attached to the 1996 and 1998                
          returns.                                                                    





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