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60(a).2 The petition was filed with the Court in the name of
petitioner by its cosettlor, Mr. Jablonski, in his stated
capacity as petitioner’s managing director.3 Petitioner
petitioned the Court to redetermine respondent’s determination of
deficiencies of $1,417,739 and $1,271,047 in its Federal income
tax for 1994 and 1995, respectively, and accuracy-related
penalties under section 6662(a) of $283,547.80 and $254,209.40,
respectively.
On June 27, 2000, we ordered petitioner to respond to
respondent’s motion by July 11, 2000, setting forth in its
response its position as to the motion and attaching any
pertinent documents in support of its position. We ordered
petitioner to list in its response the name of its trustee and a
list of its assets and liabilities as of the date of the
response. We ordered petitioner to attach to its response a copy
of the trust instrument(s) under which it has operated on or
after the date of the petition. We admonished petitioner that we
might dismiss its case if it did not comply fully with our order.
2 Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code
in effect for the years in issue.
3 The other cosettlor is Marsha Jablonski. The trust
instrument defines a settlor as “That person who is settling or
exchanging his property into the Trust Organization.”
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Last modified: May 25, 2011