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properties and parcels of land for investment. Petitioners’
oldest son, Spencer Rogers, managed petitioners’ real estate.
Petitioners had an accountant for their businesses before 1992.
Petitioners also have always had a family attorney.
B. Nikken, Inc.
Dennis Rogers used healthcare products by Nikken, Inc.
(Nikken), for back problems he has had since 1974. Nikken is a
marketing company that sells nutritional, health, and personal
wellness products. Nikken distributors sell products and earn
income by creating a network of marketers (i.e., “downline”
marketers). When downline marketers sell products, “upline”
Nikken distributors may earn a commission on the sales.
Petitioners began working as Nikken distributors in 1992 and were
very successful in 1997 and 1998.
C. The Trusts
1. Petitioners’ Purchase of Trusts
Ruth Williams (Williams), a Nikken distributor upline from
petitioners, suggested that petitioners investigate placing their
assets in trusts. In 1996, Williams and petitioners attended a
presentation by Shawn Dunn of the Aegis Co. relating to placing
their assets in trusts. Petitioners did not buy any Aegis
products or services.
Petitioners became interested in a trust package from
Advanta Strategies, which later became World Contract Services
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Last modified: May 25, 2011