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 38

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          Commissioner, supra at 1243.  In considering this factor, we look           
          to the economic realities of the arrangement to ascertain the               
          true grantor of the trust, regardless of who is named as grantor            
          in the declaration of trust.  Zmuda v. Commissioner, supra at               
          720-721; Stern v. Commissioner, 77 T.C. 614, 647 (1981);                    
          Buckmaster v. Commissioner, supra.                                          
                    1.   Pago Trust                                                   
               Although Mr. Jeter was the nominal grantor, petitioner                 
          clearly initiated the establishment of the Pago Trust.                      
          Petitioner solicited Mr. Jeter’s assistance in signing the trust            
          documents, aware of the fact that Mr. Jeter had no prior                    
          experience with trusts, and chose Mr. Norton to serve as trustee.           
          At petitioner’s direction, Mr. Jeter appointed Mr. Norton to act            
          as the trustee, having previously met Mr. Norton only once.  Mr.            
          Jeter testified that he understood that once he signed the trust            
          documents and appointed a trustee, he would play no role in the             
          management or operation of the trust.  According to Mr. Jeter, he           
          was “helping out a friend”, and since he knew nothing about                 
          trusts, he simply followed petitioner’s orders.  Further, Mr.               
          Jeter knew nothing about the Pago Trust’s business, except that             
          the trust was “some form of a tax shelter”.                                 
               In addition, only petitioner contributed property to the               
          trust, and the installment note, promissory notes, and the Prado            
          Road property were the only assets held by the Pago Trust until             






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