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International, using the number previously assigned to it. For
both 1997 and 1998, petitioner filed Forms 5500-EZ in the name of
Amnesty International, using her personal EIN and naming herself
as actuary.
Amnesty is not incorporated in the State of New Jersey or in
any other State of the United States. Petitioner is, as of
March 24, 1992, authorized to conduct a "communication service"
business in the State of New Jersey under the name "Amnesty
International". Petitioner nevertheless filed Forms 1120, U.S.
Corporation Income Tax Return, for Amnesty for 1996, 1997, and
1998. On Schedule K of the returns, it is represented that the
business activity of Amnesty is "Auditing, Bookkeeping" and the
product or service is "Research Service". According to
petitioner, "Amnesty more or less is a business and it has to do
with paralegal work that I do for myself with regard to various
[personal] lawsuits that I have come across since my car
accident".
The corporation return for Amnesty for 1996 reports as a tax
payment on line 32f, "credit from regulated investment companies"
of $5,200, and for 1997 and 1998, on line 32f, "credit for tax
paid on undistributed capital gains" in the respective amounts of
$5,840 and $10,173. Attached to each of the corporation returns
are Forms 2439, Notice to Shareholder of Undistributed Long-Term
Capital Gains, naming as the "Regulated Investment Company"
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