Scenic Wonders Gallery, LLC - Page 3




                                        - 3 -                                         

          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.                                                   







Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011