Chester H. and Michelle R. Rossman - Page 3

                                        - 3 -                                         
                                  FINDINGS OF FACT                                    
          Background                                                                  
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  At the time the petition            
          in this case was filed, petitioner resided in Cedar City, Utah.             
               In 1992, petitioner started a business, Dependable Service             
          Group Trust (DSG) d.b.a. Trustees Training Services (TTS) and               
          Trust Support Group (TSG).  Petitioner was a trustee of DSG,                
          which was formed to introduce trust products promoted by National           
          Trust Services (NTS) and Fiduciary Management Group (FMG).3                 
          These organizations hired petitioner to give seminars regarding             
          the creation and the operation of their trust products.                     
          Petitioner also conducted consultations and training with regard            
          to the creation and operation of various trust products as a side           
          business and assisted personal acquaintances in forming trust               
          arrangements.                                                               



               3 Michael D. Richmond and Rex E. Black d.b.a. FMG have                 
          promoted abusive tax schemes.  See e.g., United States v.                   
          Richmond, 90 AFTR 2d 2002-6353, 2002-2 USTC par. 50,677 (N.D.               
          Ill. 2002).  NTS and its representatives Roy Fritts and Rick                
          Prescott have also promoted abusive trust arrangements intended             
          unlawfully to avoid Federal and State income, estate, and gift              
          taxes.  See, e.g., Kooyers v. Commissioner, T.C. Memo. 2004-281;            
          Bowen v. Commissioner, T.C. Memo. 2001-47; United States v.                 
          Fritts, 97 AFTR 2d 2006-915 (N.D. Cal. 2005); United States v.              
          Green, 95 AFTR 2d 2005-572 (E.D. Va. 2004); Colby B. Found. v.              
          United States, 80 AFTR 2d 97-7689 (D. Or. 1997), affd. without              
          published opinion 166 F.3d 1217 (9th Cir. 1999).                            




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