Richards Asset Mgmt. Trust, et al. - Page 5




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          dent’s examination of those 1996 and 1997 returns and thereafter,           
          no books, records, or other information was provided to respon-             
          dent establishing the income reported and the expense deductions            
          claimed in those returns.                                                   
               James Binge (Mr. Binge) was the return preparer for each of            
          Richards Management Trust’s 1996 and 1997 trust returns, Mr.                
          Richards and Joy A. Richards’ 1996 return, and Mr. Richards’ 1997           
          return.  Mr. Binge was also listed as the return preparer for               
          Richards Charitable Trust’s Form 990-PF for the taxable year 1997           
          that was provided to respondent during respondent’s examination             
          of Richards Charitable Trust but that respondent has no record of           
          having been filed with respondent.  Respondent has identified Mr.           
          Binge as an individual involved with purported trusts used for              
          tax avoidance purposes.                                                     
               On October 16, 2000, Carol Jackson (Ms. Jackson), an attor-            
          ney authorized to practice before the Court, filed the respective           
          petitions in these cases, which she had signed on October 12,               
          2000.  On December 8, 2000, David M. Wise (Mr. Wise), an attorney           
          authorized to practice before the Court, entered an appearance in           
          each of these cases.                                                        
               On August 31, 2001, respondent filed a motion to compel                
          production of documents and a motion to compel responses to                 
          respondent’s interrogatories (respondent’s motions to compel                








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