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Background
For purposes of respondent’s motion, the parties do not
dispute the following factual allegations that are part of the
record. At all relevant times, each petitioner was a trust
engaged in business in the State of Arizona.
Petitioner Banana Moon Trust filed a Federal income tax
return for estates and trusts, Form 1041 (return), for 1995 which
was signed by Jimmy C. Chisum (Mr. Chisum) as the fiduciary or
officer representing the fiduciary. Banana Moon Trust’s 1995
return did not contain the name of the trustee or any information
that would enable respondent to determine who the trustee was.
Petitioner Purple Passion Trust filed a return for 1995
which was signed by Mr. Chisum as the fiduciary or officer
representing the fiduciary. That return did not contain the name
of the trustee or any information that would enable respondent to
determine who the trustee was.
Upon commencement of the examination of each petitioner,
respondent requested complete copies of the trust documents
relating to each such petitioner as well as other information.
Each petitioner refused to provide respondent with the trust
documents and other information requested.
Although neither petitioner provided respondent with the
documentation and other information requested, respondent’s
examining agent obtained from an unrelated third-party financial
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Last modified: May 25, 2011