Bantam Domestic Trust - Page 2




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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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