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the business assets. The equipment used in the asphalt business
was listed as an asset on the books of AMC Trust.
Joey worked in the asphalt business prior to and during the
years in issue. Commencing in about October 1996, Joey operated
the asphalt business. Joey continued to consult his parents
about various business decisions and operations, and Patricia
continued to perform services in the office. J.O. retained
custody and control of the business records.
Oliver & Co. never made a distribution to any charitable
beneficiary. After Oliver & Co. was formed, the Haneys each
received annual distributions of $3,000 from Oliver & Co. In
this connection, each year $6,000 was transferred from AMC
Trust’s bank account to Oliver & Co.’s bank account, and the
Haneys, as trustees of Oliver & Co., issued checks to themselves.
Otherwise, Oliver & Co. has never been funded with cash or other
assets.
In addition to AMC and Oliver & Co., the Haneys also formed
Jopah Trust (Jopah), TuSwanz Trust (TuSwanz), Blanco Springs
Trust (Blanco Springs), Adobe Springs Trust (Adobe), JoDon II
Trust, and H-Five Productions Trust (H-Five). Jopah leased
equipment and real property to AMC; however, rental proceeds from
AMC were reported on a Schedule C, Profit or Loss From Business,
attached to the Haneys’ returns for 1997 through 1999. For 2000
and 2001, payments by AMC to Jopah were reported on Jopah’s
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Last modified: May 25, 2011