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