- 2 - Background For purposes of respondent’s motion and petitioner’s motion, the parties do not dispute the following factual allegations that are part of the record. During its taxable year 1994, petitioner was a trust engaged in business in the State of Indiana. Peti- tioner filed a Federal income tax return for estates and trusts, Form 1041 (return), for that taxable year, which was signed by Jimmy C. Chisum as agent for the Prudent Man Trustee Co. Upon commencement of the examination of the 1994 return filed by petitioner, respondent requested petitioner to provide respondent with complete copies of the trust documents relating to it. Petitioner refused to provide respondent with the trust documents or any other type of documentary evidence regarding who was the first appointed trustee of petitioner. The notice of deficiency issued to petitioner was sent to the following two addresses: Bantam Domestic Trust Bantam Domestic Trust aka Snyder Poultry Processing aka Snyder Poultry Processing Prudent Man Trustee Company, Prudent Man Trustee Company, Trustee Trustee Post Office Box 138 Post Office Box 204 Harlan, Indiana 46743-0138 Snyder, Nebraska 68664-0204 Petitioner filed a petition in this Court which was signed on its behalf by Jimmy C. Chisum, as “Agent for Trustee Prudent Man Trustee Company”, the purported trustee for petitioner. Respondent’s motion contends in pertinent part:Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011