The petitioner formed an S corporation for his cabinet business and utilized it for over twenty years until its liquidation. Later, a "pure trust" was formed with the cabinet shop's land, building, equipment and inventory transferred to it. A series of transactions ensued with the ultimate result that petitioner did not report any tax from the transactions. The IRS asserted, and the court agreed, that the trust was a sham and that the petitioner was taxable on lease payments. Wheeler v. Comr., T.C. Memo. 2014-204.