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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:
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Last modified: May 25, 2011