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theme park, science center, and museum located in Pensacola,
Florida.
The organizational structure petitioner established for the
above activities, including petitioner’s purported religious
ministry and theme park, apparently was based on various
questionable trust documents purchased from Glenn Stoll, a known
promoter of tax avoidance schemes.1
Among other things, the trust documents petitioner utilized
provide as follows:
[a] gathering of two or more believers, in agreement
with your calling, forms a lawfully established
unincorporated association of pure trust. Upon a grant
of value, the trust must assign beneficial interest &
appoint a trustee. This trust agreement, when reduced
to writing, becomes written evidence of a Ministerial
Trust under which you may manage your personal ministry
for the church.
Petitioner has not filed individual Federal income tax
returns for 1995, 1996, and 1997.
During an audit and a criminal tax investigation that began
in the early spring of 2004, respondent concluded (1) that
petitioner appeared to be using the referred-to trust documents
as well as various nominees and sham entities for the purpose of
concealing ownership and control of his activities and
1 Aspects of Glenn Stoll’s tax avoidance schemes are
described in United States v. Stoll, 96 AFTR 2d 2005-5044, 2005-2
USTC par. 50,459 (W.D. Wash. 2005), and United States v. Stoll,
96 AFTR 2d 2005-5052, 2005-2 UTSC par. 50,460 (W.D. Wash. 2005).
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