Legal Ease, A Trust - Page 2

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               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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