AMC Trust, J.O. Haney, Jr., J.O. Haney, III and Patricia A. Haney Trustees, et al. - Page 16

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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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