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