- 4 -
respect to Richards Charitable Trust, respondent was provided
with a copy of Form 990-PF for the taxable year 1997 that showed
Richards Charitable Trust as the organization to which such form
pertained. However, as discussed above, respondent has no record
that Richards Charitable Trust filed with respondent Form 990-PF
for the taxable year 1997.
During respondent’s examination of Richards Charitable
Trust’s taxable years 1996 and 1997 and thereafter, no books,
records, or other information was provided to respondent estab-
lishing (1) the jurisdiction under the laws of which Richards
Charitable Trust was purportedly organized, (2) the person who is
authorized to act on behalf of Richards Charitable Trust, and
(3) that Richards Charitable Trust was at all relevant times a
trust cognizable for Federal tax purposes. Nor did Richards
Charitable Trust at any time provide any books, records, or other
information to respondent establishing the income shown and the
expense deductions claimed in the copy of Form 990-PF for the
taxable year 1997 that was provided to respondent during respon-
dent’s examination of Richards Charitable Trust and that showed
Richards Charitable Trust as the organization to which such form
pertained.
Joy A. Richards and Mr. Richards jointly filed Form 1040,
U.S. Individual Income Tax Return (return), for the taxable year
1996, and Mr. Richards filed a return for 1997. During respon-
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011