- 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