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petition that Photo Art Marketing Trust is the tax matters
partner (TMP) for Scenic Wonders. Photo Art Marketing Trust was
formed under the laws of the State of Arizona.
Upon commencement of the examination of the returns filed by
Scenic Wonders for taxable years 1995 and 1996, respondent
requested complete copies of the trust documents relating to
Photo Art Marketing Trust, the purported TMP for Scenic Wonders,
documentation regarding those returns, the nature of the business
of Scenic Wonders, and the relationship of Scenic Wonders to its
alleged owners, as well as other items of substantiation.
Neither the trust documents nor the other documents and informa-
tion requested was provided to respondent.
Respondent’s motion contends in pertinent part:
15. * * * all of respondent’s records regarding
the TMP trust [Photo Art Marketing Trust] indicate an
entity named D & E Sword Company is the trustee. These
records are based upon representations made by the TMP
trust to respondent in correspondence, and in represen-
tations made by the TMP trust in its petition with this
Court in a related docketed case (Docket No. 16506-98).
16. Respondent’s counsel contacted the Arizona
Corporation Commission to determine the existence/
validity of the entity called D & E Sword Company. The
Corporation Commission informed respondent’s counsel
that it had no record of any entity by that name ever
existing in the State of Arizona. Further, the Corpo-
ration Commission informed respondent’s counsel that it
had no record of any entity incorporated in Arizona
under the name of, or in reference to, an individual
named John P. Wilde.
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Last modified: May 25, 2011