- 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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