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 49

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          implausibility of the trust arrangement and petitioners’ failure            
          to provide any legitimate reason for creating the trusts.                   
               At trial, petitioner asserted that he chose the trust form             
          to conduct his businesses so that he would earn the income                  
          without incurring any liability.  However, petitioner was unable            
          to articulate any liability issues that could potentially arise             
          in the course of his businesses, which undermines petitioner’s              
          claim that asset protection was a consideration in forming the              
          trusts.  On the other hand, petitioner testified that he did not            
          expect that the McKenzie Trust’s automobile restoration business            
          would be profitable.  We find petitioner’s testimony to be                  
          completely self-serving, often contradictory, and lacking in                
          credibility.                                                                
               Petitioners further contend that petitioner formed the Pago            
          Trust to obtain foreign financing while maintaining an interest             
          in the property.  However, the record is devoid of any credible             
          evidence that the Brookes Group ever transferred any funds to the           
          Pago Trust.  To the contrary, the Pago Trust borrowed funds from            
          a variety of domestic sources in order to purchase and develop              
          the Cross Street property. Petitioner was not aware of the                  
          Brookes Group’s having ever fulfilled its commitment to provide             
          funds to the Pago Trust and could not explain why the Pago Trust            
          continued to wire funds overseas to the Brookes Group.                      








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