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$5,000. In June of 1996, Mr. Richardson applied for and received
from the Internal Revenue Service (IRS) two employer
identification numbers, one under the name of HG Asset Management
Trust and the other under the name of HG Richardson Charitable
Trust (HGRCT). Each application stated that the respective
business was started or acquired on April 1, 1996. Also in 1996,
Mr. Richardson ceased operations under the name Benefit Planning
Services and thereafter conducted any sole proprietorship
activities under the name Asset Protection Services.
On August 7, 1996, Mrs. Richardson transferred all of her
assets, real and personal, as well as her right to receive future
income and “exclusive use of my lifetime services (exception
being that of an employee situation)”, to Mr. Richardson, in
exchange for $10. On August 8, 1996, petitioners purportedly
transferred their personal residence on 758 Quailwoods Drive to
HG Asset Management Company (HGAMC).4 Petitioners continued to
reside at that location following the transfer.
By a trust instrument dated August 17, 1996, James Quay
(Mr. Quay) as creator, Mr. Richardson as investor, and Mr. Quay
and Mrs. Richardson as acceptors and initial directors
established HGAMC as a “Common Law Business Organization”.
Mr. Quay was an attorney whom Mr. Richardson had met at an Aegis
4 The parties stipulated this fact, but because no documents
dated Aug. 8, 1996, related to the transfer are contained in the
record, any specifics and/or incongruities remain unexplained.
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Last modified: May 25, 2011