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60(a).2 The petition was filed with the Court in the name of
petitioner by Mr. Jablonski, in his stated capacity as
petitioner’s contractor. Petitioner is purportedly an
irrevocable trust, the settlor of which is Marsha Dulaney
Jablonski.3 Petitioner petitioned the Court to redetermine
respondent’s determination of deficiencies of $19,007 and $18,988
in its Federal income tax for 1995 and 1996, respectively,
accuracy-related penalties under section 6662(a) of $3,801.40 and
$3,797.60, respectively, and additions to tax under section
6651(a)(1) of $950.35 and $949.40, respectively.
On June 27, 2000, we ordered petitioner to respond to
respondent’s motion by July 11, 2000, setting forth in its
response its position as to the motion and attaching any
pertinent documents in support of its position. We ordered
petitioner to list in its response the name of petitioner’s
trustee and a list of petitioner’s assets and liabilities as of
the date of the response. We ordered petitioner to attach to its
response a copy of the trust instrument(s) under which it has
operated on or after the date of the petition. We admonished
2 Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code
in effect for the years in issue.
3 Ms. Jablonski is also listed in a document dated May 17,
1994, entitled “MINUTES OF THE INITIAL TRUSTEE MEETING OF MALVERN
HILLS TRUST”, as petitioner’s managing director.
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