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Percy thank you good morning artists my name is Robert Johnson from the fervour gray Robinson representing the appellate we are here today discussing matters that really a curse started in 2002 and that's when the decedent Jerome Rudin with the assistance of three lawyers one in Ohio one in Pennsylvania and one in Florida executed documents to implement what was described by the Florida lawyer as mr. Rubens a state plan he wanted to roll over his IRA into his pension plan which he formed in 2002 he executed in two thousand to the forum investments retirement plan the Fordham investments retirement plan trust and established fornum Investments Inc in which he was the president his spouse was the vice president and his florida attorney mr. Nemec was the secretary is there a tax advantage to the rollover I don't know the answer to that obviously he made a determination that this would be the better place with the guidance of his lawyers to place the money that he had in the IRA I'm just curious as to why that is an advantage and I apologize i mean the litigator and not the tax lawyer and I don't know the theory I'm specifically behind that whether it would be substantial tax savings for him over the years again the problem that we do face now is that if in fact the lower court ruling is correct that would then roll over within the income to mr. Wooten 2002 and that's what our major concern is here today and in addition to that what has happened is the plan that mr. Rudin has put into place signing all of these documents would be destroyed a question though here really it seemed to me and I don't mean to get to the point that I'm that kind of a guy you don't mind I just kind of like I get that a point the point really is is this a viable corporation because the corporation must be viable to sustain the tax advantage and the question is does a state probate court cinnamon its probe a jurisdiction have a right to make that determination or is it undermining the letter ruling given by the IRS and I think those are separate issues I think a state probate court sitting and with probate jurisdiction exclusively has the right to determine what assets are in an estate and what assets are not in an estate and if it and also has the right to determine is a corporation with a Bible form is it operable is it really a corporation at all and if not then the assets of that corporation are not inside that corporate entity so so the issue is i'm shannon you've taken the position is how can a state court sitting in probate undermine the IRS is letter ruling which said this is an authorized plan with me on dis corporation it was a qualified letter quick at the time it said the corporation for the moment is fine and then we sort of have this process later on were even the decedent and his wife sort of talk to mr. not our communicate with mr. niacin have we done enough to sort of foot this corporation and he said no yeah you need to do more so won't you take it from...