- 2 - 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)Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011