Homer L. Richardson - Page 6

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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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