Homer L. Richardson - Page 55

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               Concerning explanations for behavior, petitioners, other               
          than offering a few broad, general statements, have made little             
          attempt to justify or illuminate the rationale underlying their             
          association with the Aegis system.  Certain inconsistencies,                
          however, give us pause.  Mr. Richardson at trial testified that             
          he had consulted with several independent tax professionals                 
          before purchasing the Aegis trust package, but in response to a             
          previous interrogatory from respondent requesting identification            
          of persons from whom advice was secured prior to creation of the            
          trusts had listed only individuals connected with Aegis.                    
          Mr. Richardson’s testimony that he became uncomfortable in late             
          1999 or 2000 with arguments being asserted by Aegis in                      
          conjunction with challenges to the trust structure and began to             
          disengage from those positions is likewise suspect.                         
          Mr. Morgason’s description of Mr. Richardson’s behavior during              
          the 2002 section 6700 investigation is to the contrary and is               
          corroborated by audio recordings of conferences conducted                   
          pursuant thereto.                                                           
               Concealment of income and assets is at the crux of this                
          litigation and requires little further discussion.  The                     
          establishment of a trust structure without economic substance, to           
          which income and assets are transferred for tax avoidance                   
          purposes, has been considered by this Court to be an affirmative            
          indicium of fraud.  Mason v. Commissioner, T.C. Memo. 2004-247;             
          Dunlap v. Commissioner, T.C. Memo. 1993-187; Brittain v.                    




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