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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 Morgan, Kramer & Strauss, LLC (Morgan,
Kramer), as the fiduciary, 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
Morgan, Kramer 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
that pursuant to Rule 60, Mr. Wilde is not the proper party to
bring this action.
1 References to “petitioners” are to Troy Enterprises Trust
and Yale Enterprises Trust.
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Last modified: May 25, 2011