NHUSS Trust, et al. - Page 6

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          of an automotive leasing and rental business, and certification             
          in the International Automotive Appraisers Association.                     
               Mr. Sobrero’s appraisal of petitioners’ van consisted of a             
          visual inspection.  Mr. Sobrero, however, did not take into                 
          account in his appraisal the mileage of the van.                            
               On December 16, 2000, 6 weeks after receiving the donated              
          van from petitioners, the van was sold at auction by the Vehicle            
          Donation Processing Center, Inc., for $6,900.                               

          Negligence Penalty and Petitioners’ Three Trusts                            
               During 1999 and 2000, petitioners were engaged in the                  
          wholesale furniture business in Nevada and northern California.             
          For more than a decade before 1997, petitioners operated their              
          furniture business as a corporation called NHUSS, Inc.  In 1997,            
          petitioners dissolved NHUSS, Inc., and began operating their                
          furniture business through a trust called the NHUSS Trust.                  
               In a brochure distributed by National Trust Service (NTS),             
          founded and promoted by one Roy Fritz, NTS claimed that taxpayers           
          could “with [their] custom designed NTS Trust Document * * *                
          regain [their] inalienable rights and freedoms” by attending an             
          NTS workshop where they would learn to create their own trusts              
          that purportedly would protect taxpayers’ assets while lowering             
          or eliminating their tax liabilities.  Petitioners paid                     
          approximately $10,500 to attend the NTS workshop.  Mr. Fritz                
          claimed to be a lawyer and “world authority on complex trusts.”             





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