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For each trust year in question, such income distribution
deduction, along with a charitable contribution deduction of $860
for 1994, was sufficient to reduce reported taxable income to
zero. A tax liability of zero was reported for each trust year,
1992 through 1995.
Rita Snyder’s Business
During the years in issue, Rita Snyder engaged in business
as a paid tax return preparer, under the name “Complete
Connections”.
Complete Connections Checking Account
A business checking account, account number 002-502704, in
the name of “Complete Connections” (the Complete Connections
checking account), was opened at Santa Lucia National Bank no
later than August 9, 1990, and was closed on January 28, 1999.
The signature card for that account describes the account as a
trust account and shows as signatories both Rita and James
Snyder, each of whom is described as a manager. All checks drawn
on the Complete Connections checking account during 1995 were
signed by either James or Rita Snyder.
Federal Income Tax Return for J&R Trust
Beginning with 1992, and continuing for 1993, 1994, and
1995, either Rita or James Snyder made a return of income on
Form 1041, U.S. Fiduciary Return of Income (for 1992 and 1993) or
U.S. Income Tax Return for Estates and Trust (for 1994 and 1995),
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