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stated that respondent had no record of receiving Form 1041, U.S.
Fiduciary Income Tax Return (Form 1041), for either of the two
trusts for the tax periods ended 1995 and 1996. Revenue agent
Arnold further stated in those two letters:
If you are required to file the returns, but have not
done so, we are requesting these returns to be filed by
May 16, 1997. Please submit the following information
by May 16, 1997 * * *.
- Completed returns
- A copy of the managing agent’s compensation
agreement referenced in the trust agreement
- A copy of Schedule A and the Addendum referred
to in the trust document
* * * * * * *
If you were not required to file returns for the peri-
ods indicated, please explain why you are not [sic]
longer liable in the space provided below.
On May 8, 1997, Mr. Barmes responded to revenue agent
Arnold’s two letters dated May 1, 1997. Mr. Barmes made identi-
cal responses in the space provided on the second page of each of
revenue agent Arnold’s two letters dated May 1, 1997. That
response consisted of the following statement: “No beneficiary
disbursements made. No K-1's necessary.”
On May 14, 1997, revenue agent Arnold issued a letter
addressed to “Marvin and Barbara Barmes, Managing Agents” (reve-
nue agent Arnold’s letter dated May 14, 1997). That letter
stated in pertinent part:
We have received your response on May 9, 1997 to our
May 1, 1997 letters requesting the tax returns (1041)
for Sandbar Wholesale Trust and Sandbar Real Estate
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