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questions raised by this litigation comes to light.
Mr. Richardson was not a mere participant in or purchaser of a
mass-market trust scheme; he was an active promoter. He traveled
throughout a multistate area lending his prestige and expertise
to and conducting seminars on the Aegis system. He thus was
necessarily intimately acquainted with the details of the program
and the intended benefits. The advertising materials make clear
that tax reduction was emphasized above all other advantages.
This was amply corroborated by the credible testimony of
Mr. Young, who attended a number of seminars involving Mr. Graham
and Mr. Richardson and who purchased first a trust package from
Aegis and later additional management services from
Mr. Richardson. In his words, “the main thrust was to save money
on your taxes as much as 70 percent.” Mr. Richardson’s demeanor
at trial and disingenuous attempts to distance himself from the
Aegis organization, on the other hand, were singularly
unconvincing.
The preeminence of tax considerations in Mr. Richardson’s
implementation of the Aegis system is likewise corroborated by
materials contained in the minutes of HGAMC board meetings. The
quantity of statements addressing tax matters is telling. Even
more revealing is the specific content of the June 27, 1997,
minutes. This document shows that within a few weeks of filing
his 1996 return and long before the 1997 return was filed,
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