- 59 - 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 EstatePage: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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