United States v. Ottaviano, Nos. 11-4553 and 13-1119; Third Circuit; opinion by Hardiman, U.S.C.J.; filed December 24, 2013. Before Judges Ambro, Fisher and Hardiman. On appeal from the District of New Jersey, No. 10-cr-00485. [Sat below: Judge Martini.] DDS No. 14-8-xxxx [24 pp.]

Through his company, Mid-Atlantic Trusts and Administrators, defendant Ronald Ottaviano offered financial products he claimed would help others elude the Internal Revenue Service and have the government pay their debts. The principal offering was the Pure Trust Organization (PTO), which Ottaviano marketed as a means to hide assets from creditors and the IRS. Although PTOs appeared to be legitimate trusts, in actuality customers had unlimited access to and control over the accounts—which made them sham trusts.