Dennis L. Rogers and Charlotte Rogers - Page 5

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               donate up to 100% of their income to charity which is                  
               another way to lower tax liability.                                    
          Becker gave petitioners a WCS booklet entitled “Structuring Your            
          Practice for Profit, Privacy & Protection” which described, inter           
          alia, substantial income and estate tax savings by using trusts.            
               On a date not stated in the record, petitioners paid $15,000           
          to Becker for a trust package from WCS which included a business            
          trust known as Global Wellness Trust (Global Wellness), a primary           
          trust known as Wealth Unlimited Investments Trust (Wealth                   
          Unlimited), and 20 holding trusts.  Petitioners created Global              
          Wellness on December 1, 1996.  Petitioners completed a WCS new              
          client application and trust purchase agreement on April 3, 1997.           
          Petitioners appointed James Galligan (Galligan) and Secured                 
          Protections, Inc., as cotrustees for Global Wellness.                       
          Petitioners appointed Galligan and Real Protections, Inc., as               
          trustees for Wealth Unlimited.  Becker was trustee for Real                 
          Protections, Inc.                                                           
               2.   Operating the Trusts                                              
               Petitioners purportedly conveyed to the trusts all of their            
          personal assets, real estate assets, and assets related to their            
          Nikken sales distributorship.                                               
               During the years in issue, petitioners used money                      
          distributed to Wealth Unlimited from Global Wellness to improve             
          their principal residence and to make double payments on the                
          mortgage on their principal residence.                                      





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