Homer L. Richardson - Page 15

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               The record also contains an example of an announcement for             
          an advanced business trust workshop sponsored by HGAMC in Ohio in           
          1999.6  Mr. Richardson sent out an invitation stating:                      
               I am writing to let you know about an ADVANCED BUSINESS                
               TRUST WORKSHOP that HG Asset Management Company is                     
               sponsoring.  This workshop will be conducted by Mike                   
               Vallone, the Executive Director of Aegis.  It will be                  
               three full days from 9 a.m. until 5 p.m. each day                      
               devoted to the complete CBO System.  This workshop goes                
               beyond what you may have learned at the Basic CBO                      
               Workshop given by Homer Richardson and Wil Graham.  You                
               will study how to properly move money through the                      
               system, and how you should operate the charitable                      
               trust.  We will show you how Offshore entities, such as                
               offshore trusts, and International Business Companies                  
               can be used in connection with this system to get                      
               incredible tax advantages, as well as even greater                     
               privacy and protection from the IRS.  In fact, we will                 
               show you how to create a CBO that has NO tax reporting                 
               requirements in the U.S.                                               
               To provide ongoing support to clients who purchased trust              
          packages, petitioners as directors of HGAMC at a December 29,               
          1998, board meeting affirmed and ratified the creation of a                 
          department within HGAMC to provide management services, to be               
          known as Trust Management Services.  A bank account had been                
          opened in the name of HG Asset Management Co. d.b.a. Trust                  
          Management Services on June 29, 1998, at Lebanon Citizens                   
          National Bank, over which petitioners had signatory authority.              
               Subsequently, in February of 2000, the structure of                    
          petitioners’ entities was again altered with the creation of                


               6 An apparently similar seminar conducted in 1998 was                  
          approved by the Ohio Supreme Court Commission on Continuing Legal           
          Education for 19.5 hours of CLE credit.                                     




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