Michael R. and Helen G. Joseph - Page 4

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               On March 7, 1995, petitioners transferred1 the property to             
          the Trust for a stated sale price of $300,000.  Petitioners                 
          received the $300,000, the ultimate source of which, however, is            
          not established in the record.  Petitioners deposited the                   
          $300,000 into their personal bank account.                                  
               Prior to transferring the property to the Trust, petitioners           
          did not attempt to list the property for sale with a realtor or             
          otherwise attempt to market or to sell the property.                        
               With the transfer of the property to the Trust, petitioners            
          retained an option to repurchase the property for an unstated               
          amount, which option they recorded.  Petitioners purportedly paid           
          the Trust $100 for the option.                                              
               Petitioners also transferred to the Trust two building                 
          permits that had been issued to petitioners on October 18, 1993,            
          and February 1, 1995, by the city and county of Honolulu,                   
          authorizing construction of petitioners’ residence on the                   
          property.  Architectural plans and drawings for the residence,              
          soil reports, and other reports also were transferred to the                
          Trust.                                                                      
               Between March of 1995 and April of 1996, approximately                 
          $600,000 was spent on the construction of a residence on the                


               1 The use in our Findings of Fact of the words “transfer”              
          and “repurchase” (and other forms thereof) is not intended to               
          constitute findings as to the true nature of the transactions               
          between petitioners and the Trust.                                          





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