Universal Trust 06-15-90 - Page 7




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                    fiduciary or for the entity claimed to be petitioner’s                                                                                                 
                    beneficiary.7                                                                                                                                          
                              The Form 1041 stated that petitioner’s 1993 business gross                                                                                   
                    receipts were $83,075.  It also stated that petitioner was                                                                                             
                    entitled to deductions for $51,865 of expenses and $31,210 of                                                                                          
                    income distributions, leaving a claimed taxable income of zero.                                                                                        
                    The Form 1041 further stated that the distributions were made to                                                                                       
                    a beneficiary named “Oak Hargor [sic] Finance”, with the                                                                                               
                    following address:  “P.O. Box 577, Guelth [sic], Ontaria [sic]                                                                                         
                    Canada N1H 6K9".                                                                                                                                       
                              On December 1, 1997, respondent sent the statutory notice to                                                                                 
                    petitioner.  The notice was addressed as follows:                                                                                                      
                              Universal Trust 06-15-90                                                                                                                     
                              Care of Four WS TT01 Trustee                                                                                                                 
                              3531 West Glendale Avenue, Unit 347                                                                                                          
                              Phoenix, AZ 85051-8332                                                                                                                       
                                                                                                                                                                          
                    The notice determined that petitioner had $21,711 of unreported                                                                                        
                    gross receipts.  Taking into account the $83,075 of gross                                                                                              
                    receipts reported on the Form 1041, the notice to petitioner                                                                                           
                    determined that petitioner’s actual 1993 gross receipts were                                                                                           
                    $104,786.  The notice stated that the amount of petitioner’s                                                                                           

                              7 The record also contains a copy of a Form 8800,                                                                                            
                    Application for Additional Extension of Time to File U.S. Return,                                                                                      
                    relating to the Form 1041.  This Form 8800 was signed by Mr.                                                                                           
                    Chisum as “T/E Agt.” (presumably, as “trustee’s agent”).  Like                                                                                         
                    the Form 1041, the Form 8800 did not identify petitioner’s                                                                                             
                    trustee or trustees.                                                                                                                                   






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Last modified: May 25, 2011