Michael Mariani, V. State Of Wa, Dept. Of Financial Institutions

CourtCourt of Appeals of Washington
DecidedMay 5, 2025
Docket87072-6
StatusPublished

This text of Michael Mariani, V. State Of Wa, Dept. Of Financial Institutions (Michael Mariani, V. State Of Wa, Dept. Of Financial Institutions) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Mariani, V. State Of Wa, Dept. Of Financial Institutions, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

MICHAEL MARIANI and PRESTIGE No. 87072-6-I MANAGEMENT LLC,

Appellants, DIVISION ONE

v. PUBLISHED OPINION DEPARTMENT OF FINANCIAL INSTITUTIONS,

Respondent.

SMITH, J. — Gary and Irene Cline owned real estate in Washington which

they had decided to sell. To increase the proceeds of the sale of that real estate

and to defer taxes, the Clines invested in a deferred sales trust. Michael Mariani

and Prestige Management, LLC, helped establish that trust and served as

trustees for the account. Following review of the trust, the Department of

Financial Institutions determined that the deferred sales trust and accompanying

promissory note were securities not properly registered as such. The

Department similarly determined that Mariani was not registered as a securities

salesperson or broker-dealer. The Department ordered a fine as well as costs

and fees. Mariani and Prestige petitioned for review of the order in superior

court. The trial court affirmed the findings of the Department in their entirety.

Mariani and Prestige appeal, asserting that the Department erred in determining

that the deferred sales trust constitutes a security, that Mariani offered or sold a No. 87072-6-I/2

security, and that no exemption for registration exists. Finding no error, we

affirm.

FACTS

Deferred Sales Trust

A deferred sales trust (DST) is a tax-deferral concept created by Todd

Campbell.1 The concept relies on Section 453 of the Internal Revenue Code and

a private letter ruling from the Internal Revenue Service. The letter ruling

provides that income on an “installment sale” is not considered earned on an

asset until the seller actually receives payment. By deferring the receipt of the

purchase payment, the seller may defer paying taxes on any gain. This

particularly appeals to owners whose property has dramatically appreciated in

value since the original purchase. Without the use of a DST, the owners face

substantial tax liability given the capital gains triggered by the sale of the

property.

In a standard DST, the seller wants to sell an asset that has substantially

appreciated in value but defer taxation on the gains from that sale. The structure

used in a DST, including whether or not to utilize a promissory note, varies by

transaction. The attorney for the seller is responsible for advising the client on

how the specific DST is structured and drafting the necessary documents.

A DST involving a promissory note requires that the seller’s attorney

create a trust, which acquires the appreciated asset from the seller, and a

1 The parties stipulated to the facts about the basics of a DST and the creation of the Lake Cavanaugh Trust.

2 No. 87072-6-I/3

promissory note from the trust in favor of the seller. The note obligates the trust

to pay the seller the specified sales price, simply at a later time. The seller’s

attorney then works with the seller to determine when and how they would like to

be repaid. Unless and until the seller actually receives payment from the trust,

the seller need not pay any tax.

Once the appreciated property is transferred to the specifically-created

trust, the trust often sells the property to a third-party buyer for cash. The third-

party buyer may purchase the asset in a lump sum or in installments, the latter of

which will fund the trust over time. Either way, the trust will invest the proceeds

of the sale, seeking a return on the investment designed to: (1) meet its particular

obligations under the promissory note to pay the seller the agreed upon sales

price plus a set interest rate, and (2) build additional returns on the invested sale

proceeds. The trust must retain the amounts earmarked for payment of the

promissory note.

Lake Cavanaugh Trust

In 2013, Gary and Irene Cline decided to sell their vacation property (Lake

Cavanaugh Property). The Lake Cavanaugh Property had substantially

appreciated in value since the Clines bought the property in the 1970s. Originally

purchased for $15,000, the Lake Cavanaugh Property was now worth over

$200,000. Concerned with the amount of tax they would have to pay upon sale,

the Clines learned about DSTs through their financial advisor. Their financial

advisor referred them to Bob Binkele, who, in turn, referred them to Campbell.

The Clines then retained Campbell as their attorney. In accordance with his

3 No. 87072-6-I/4

normal practice, Campbell prepared the documents necessary to create a trust

(Lake Cavanaugh Trust) to acquire the Lake Cavanaugh Property.

In August 2013, Campbell procured Michael Mariani and Prestige, LLC,2

an accountant and accounting firm respectively, to establish and act as trustee to

the Lake Cavanaugh Trust. Campbell served as Prestige’s attorney. After

engaging Prestige, Campbell sent the Clines drafts of several documents

necessary both to complete the sale of the Lake Cavanaugh Property and to

transfer the assets to the trust. This included draft promissory notes. Campbell

ultimately sent the Clines five different draft promissory notes over the following

six months. Each defined the amount of the principle and provided that interest

would accrue at a rate of eight percent. In addition to the multiple drafts,

Campbell sent the Clines a variety of e-mails concerning the status of the

promissory note. The Clines did not sign any of the draft promissory notes or

provide a payment schedule.

Nevertheless, the Clines sold the Lake Cavanaugh Property to the Lake

Cavanaugh Trust. In October 2013, Prestige sold the property to third-party

buyers. The buyers provided a $50,000 down payment with an additional

$188,000 to be paid in installments. The proceeds of that sale were deposited

with the Lake Cavanaugh Trust as they were received. Mariani, as an individual,

had no direct communication with the Clines until after the Lake Cavanaugh

Property sold.

2 As Mariani acted in his role as an accountant for Prestige, we refer to them collectively as “Prestige.”

4 No. 87072-6-I/5

Once the proceeds from the property funded the trust, Prestige retained

Binkele to provide the Lake Cavanaugh Trust with investment recommendations.

As trustee, Prestige was required to preserve the trust’s assets while also hoping

to make more money than the promissory note required the trust to pay the

Clines. Although the parties did not formally execute a promissory note, all acted

as if one existed.

Administrative Review

In 2017, the Cline’s insurance agent reviewed their holdings and

expressed concern about the DST structure and lack of promissory note. In

response, the Clines requested that Prestige liquidate the holdings of the Lake

Cavanaugh Trust and distribute the proceeds. The Clines then brought a

complaint to the Department. The Department opened an investigation in July

2017.

Following the Department’s investigation, it issued a statement of charges

concluding that the Lake Cavanaugh DST constituted the offer and/or sale of a

security rather than a trust. The Department similarly concluded that Prestige

sold unregistered securities, that Mariani offered and sold securities without

registering as a securities broker, and that the operation of the trust constituted

fraud.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Reves v. Ernst & Young
494 U.S. 56 (Supreme Court, 1990)
Securities & Exchange Commission v. Edwards
540 U.S. 389 (Supreme Court, 2004)
State v. Philips
741 P.2d 24 (Washington Supreme Court, 2009)
Cellular Engineering, Ltd. v. O'Neill
820 P.2d 941 (Washington Supreme Court, 1991)
State v. Saas
820 P.2d 505 (Washington Supreme Court, 1991)
McClellan v. Sundholm
574 P.2d 371 (Washington Supreme Court, 1978)
Cantu v. Department of Labor & Industries
277 P.3d 685 (Court of Appeals of Washington, 2012)
Helenius v. Chelius
120 P.3d 954 (Court of Appeals of Washington, 2005)
Karanjah v. Department of Social & Health Services
199 Wash. App. 903 (Court of Appeals of Washington, 2017)
Southwick, Inc. v. Wash. State
426 P.3d 693 (Washington Supreme Court, 2018)
Ames v. Department of Health
208 P.3d 549 (Washington Supreme Court, 2009)
Helenius v. Chelius
120 P.3d 954 (Court of Appeals of Washington, 2005)
Cantu v. Department of Labor & Industries
168 Wash. App. 14 (Court of Appeals of Washington, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Michael Mariani, V. State Of Wa, Dept. Of Financial Institutions, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-mariani-v-state-of-wa-dept-of-financial-institutions-washctapp-2025.