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Trust and that petitioner was its true grantor. Petitioner
arranged for Mr. Hartmann to act as the trust’s creator, and
petitioner selected Mr. Boatright, a personal friend whom
petitioner knew to be unfamiliar with trusts, to serve as
trustee. Mr. Hartmann appointed Mr. Boatright as trustee without
having met him before signing the trust documents. Further, the
record is devoid of any evidence that anyone other than
petitioner, who contributed his services and technical expertise
in restoring automobiles, transferred any property or services to
the McKenzie Trust. Therefore, we find that petitioner was the
true grantor of the McKenzie Trust. See Zmuda v. Commissioner,
79 T.C. at 720-721; Buckmaster v. Commissioner, T.C. Memo. 1997-
236.
Before forming the trust, petitioner had operated Brassworks
as a sole proprietorship. After selling Brassworks to the
Ingallses, petitioner returned to the automobile restoration
business and operated it under the name of “McKenzie Trust,
Charles Boatright, Trustee”. Although petitioner no longer
fabricated radiators, he continued to restore Model T Fords.
Further, petitioner continued to receive essentially all of the
profits from the automobile restoration business in the form of
management fees. The only apparent difference in petitioner’s
conduct of the business after he formed the trust was that he
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