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FINDINGS OF FACT
Background
The exhibits2 of the parties are incorporated herein. These
cases were consolidated for purposes of trial, briefing, and
opinion. At the time these petitions were filed, petitioners
resided in Gove, Kansas.
Respondent issued petitioners notices of deficiency for the
1999 taxable year on March 24, 2003, and for the 2000, 2001, and
2002 taxable years on January 6, 2004. Petitioners timely filed
a petition on September 8, 2003, for the 1999 taxable year and a
petition on April 8, 2004, for the 2000, 2001, and 2002 taxable
years.
Larry J. Lundgren (Mr. Lundgren) was a farmer, and Anita L.
Lundgren (Mrs. Lundgren) was a registered nurse and the secretary
of the Lucky Kirt Trust from 1999 through at least a portion of
2001.
The Lucky Kirk trust was formed at the request of Raymond
Roemer, father of Mrs. Lundgren, and was allegedly created on
October 11, 1990. Neither of petitioners was present during the
formation of the trust or the signing of the trust document.
Dennis Roemer, brother of Mrs. Lundgren, was present during trust
formation discussions between his father and Jimmy Clayton
2 Although requested by the Court, the parties did not file
a stipulation of facts. On the basis of religious beliefs, Mr.
Lundgren refused to stipulate anything except petitioners’ names.
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Last modified: May 25, 2011