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“disclaimer”, as to which J.O. testified: “I would assume it
came from Karl Dahlstrom”. The Haneys denied that they discussed
tax avoidance with Dahlstrom. Dahlstrom, however, had been in
the abusive trust business for many years. See, e.g., Akland v.
Commissioner, 767 F.2d 618 (9th Cir. 1985), affg. T.C. Memo.
1983-249; United States v. Dahlstrom, 713 F.2d 1423 (9th Cir.
1983); Dahlstrom v. Commissioner, T.C. Memo. 1991-264 and 1991-
265, affd. without published opinion 999 F.2d 1579 (5th Cir.
1993). The Haneys claim that they did not know of Dahlstrom’s
history. Whether they did or did not know of the reported cases,
we do not believe that Dahlstrom did not use tax avoidance as an
objective in promoting his trust schemes. In addition, the lack
of credibility in J.O.’s testimony is demonstrated by the
following colloquy:
Q [respondent’s counsel] Mr. Haney, so
Mr. Dahlstrom did not mention anything about using the
trusts would–-about the trusts providing tax savings?
A [J.O.] Not to my knowledge. Define tax
savings.
Q Sir, are you saying that he did not say it or
do you not remember him saying it?
A I don’t remember him saying it, but what-–what
do you mean, talk about? What--
Q Did he mention taxes, federal income taxes, at
all in his presentations?
A He mentioned that each trust should have an EIN
number so they could do their tax returns.
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