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gross receipts was determined using the bank deposits method.
The notice also disallowed, for lack of substantiation, the
$51,865 expense and $31,210 distribution deductions claimed on
the Form 1041. As a result of these adjustments, the notice
determined that there was a $37,312 deficiency in petitioner’s
income tax and that petitioner was liable for a $7,462 accuracy-
related penalty under section 6662(a).
As previously indicated, see supra p. 4, we have held that
most of the income that is the subject of the three “whipsaw”
notices, including the notice in the case at hand, is properly
taxable to Mr. Johnston, and that all but $25 of the balance was
paid for work done by Ms. Ghavami. See Johnston v. Commissioner,
T.C. Memo. 2000-315.
Facts Relating Primarily to Respondent’s Motion To Dismiss
As noted above, the original indenture provided that Four WS
TT01 was petitioner’s first trustee.
The record contains almost no information about Four WS
TT01.8 Mr. Chisum testified that Four WS TT01 is a trust, and
that Mr. Chisum was (and is) its managing agent and trustee.
However, Mr. Chisum did not offer and the record does not contain
any trust indenture, corporate charter, partnership agreement, or
8 In response to the Court’s question at the hearing,
Mr. Chisum testified that the “Four WS” in the name Four WS TT01
stood for the question-phrase “What’s Wrong With White?”
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