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all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Petitioners1 are trusts organized under the laws of Arizona.
On September 9, 1996, each petitioner filed a 1995 U.S. Income
Tax Return for Estates and Trusts (collectively, the returns).
The returns listed Stein & Stein as the trustee, and Cliff
Jennewin signed the returns as the “trustee agent”.
Upon commencement of the examinations of the returns,
respondent requested complete copies of the trust documents from
petitioners. Petitioners failed to provide any trust documents
and to cooperate in any way during the examinations.
On September 1, 1999, respondent issued separate notices of
deficiency to petitioners. The notices of deficiency identified
Stein & Stein as trustee of both trusts.
On November 29, 1999, petitioners filed a joint petition in
this Court. John P. Wilde (Mr. Wilde) signed the petition on
behalf of petitioners, wherein he identified himself as
“trustee”.
On January 27, 2000, respondent filed a motion to dismiss
for lack of jurisdiction (respondent’s motion) on the grounds
1 References to “petitioners” are to Renaissance
Enterprises Trust and Educational Enterprises Trust.
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Last modified: May 25, 2011