Renaissance Enterprises Trust - Page 2




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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