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U.S. v. PATRIDGE

Nos. 06-3635, 06-3785.

507 F.3d 1092 (2007)

UNITED STATES of America, Plaintiff-Appellee, v. Denny R. PATRIDGE, Defendant-Appellant. Denny R. Patridge and Judy Patridge, Petitioners-Appellants, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided November 14, 2007.

Attorney(s) appearing for the Case

Gregory V. Davis (argued), Alan Hechtkopf, U.S. Dept. of Justice, Tax Division, Appellate Section, Washington, DC, for Plaintiff-Appellee.

Jerold W. Barringer (argued), Nokomis, IL, for Defendants-Appellants Denny and Judy Patridge.

Patricia M. Bowman, U.S. Dept. of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee C.I.R.

Before EASTERBROOK, Chief Judge, and WOOD and EVANS, Circuit Judges.

EASTERBROOK, Chief Judge.

Denny Patridge, who owned an insurance agency, decided to make life hard for the revenooers by transferring his income to an offshore trust and then pretending that he had no income. The first trust in line, located in Antigua, transferred everything to a second trust, in Belize. The second trust transferred the money to a third trust (also in Belize), which "loaned" it back to Patridge, who conveniently...

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