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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, the mailing address for peti-
tioner was in Arizona.
Petitioner filed a Federal income tax return for estates and
trusts, Form 1041 (return), for taxable year 1994. Although the
portion of the first page of that return requesting petitioner to
identify the “Name and title of fiduciary” was left blank, that
return was signed by Dennis H. Lawrence as “fiduciary or officer
representing” trust. Petitioner’s 1994 return was also signed by
R.W. Buchanan as paid return preparer. In the Schedule K-1
attached to the 1994 return filed by petitioner, the beneficiary
was identified as “BULL HOLDINGS A TRUST”, but no fiduciary was
identified as required by that schedule.
Upon commencement of the examination of petitioner’s taxable
year 1994, respondent requested complete copies of the trust
documents relating to petitioner as well as other items of
substantiation. Petitioner refused to provide respondent with
the trust documents and other information requested.
On March 4, 1998, petitioner filed with the Internal Revenue
Service Form 2848, Power of Attorney and Declaration of Represen-
tative. That form, which pertained to petitioner’s taxable years
1994, 1995, and 1996, was signed by James R. Slagle (Mr. Slagle)
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Last modified: May 25, 2011