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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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