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During the evidentiary hearing in this case, petitioner
offered to the Court a document purportedly reflecting Cypress
Management’s resignation as trustee for Fennel Trust, as well as
a document purportedly reflecting Cypress Management’s
resignation as trustee for Tarragon Trust. Considering that
these documents were undated, as well as other discrepancies in
the record, the documents were not admitted into evidence.8
On April 30, 1994, Fennel and S&T Management purportedly
executed a document entitled “INDEPENDENT COMMON-LAW CONTRACTOR
CONTRACT”, in which S&T Management and Fennel were identified as
contractor and client, respectively.
Fennel did not file a U.S. Fiduciary Income Tax Return, Form
1041, for 1995 and 1996.9 However, for those years, Fennel
received a Schedule K-1, Beneficiary’s Share of Income,
Deductions, Credits, etc., from BHC Trust, another “business
trust organization” whose purported trust instrument was the work
of Zola Sheehan. The Schedule K-1 for 1996 reflects a loss in
the amount of $2,180. Paul and Rosaria Jablonski attached this
Schedule K-1 to their Federal income tax return for 1996 and used
8 The document offered with respect to Tarragon Trust
differed in material respects (including signatories and
typeface) from another document that Tarragon Trust had offered
to reflect Cypress Management’s resignation as trustee.
9 Indeed, Fennel did not file an income tax return from its
inception through 1999.
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