- 4 - petitioner.4 The CM Trust agreement stated that CM Trust was irrevocable. The CM Trust agreement also stated that Kevin Murphy was CM Trust’s settlor and that Michael Murphy and Lester Detterback were CM Trust’s trustees. Ovation is an Illinois general partnership that was formed on October 27, 2000, and that was liquidated on December 20, 2000. Ovation’s listed owners were four single-member limited liability companies (LLCs). The LLCs, their members, and their interests in Ovation were as follows: LLC Member Interest Fender Trading, LLC Kevin Murphy 68% CPM Gibson Trading, LLC CM Trust 13 Martin Trading, LLC Christopher Murphy Trust 13 Ibanez Trading, LLC Michael Murphy 6 On August 31, 2001, petitioner filed his 2000 Federal income tax return. The return reported CM Trust’s tax attributes (e.g., income and deductions) as if CM Trust was petitioner’s grantor trust; i.e., the return reported the items as if they had been realized directly by petitioner. On September 9, 2001, CM Trust filed a 2000 Form 1041, U.S. Income Tax Return for Estates and Trusts, reporting that CM Trust was petitioner’s grantor trust for Federal income tax purposes. The trust return included a “GRANTOR LETTER” identifying petitioner as the grantor of CM Trust and stated on its face that “UNDER THE TERMS OF THE TRUST 4 The CM Trust agreement lists petitioner’s name with two “l”s instead of one.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007