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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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