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books, records, or other reliable information was provided to
respondent establishing (1) the jurisdiction under the laws of
which Herbst Management Trust was purportedly organized, (2) the
person who is authorized to act on behalf of Herbst Management
Trust, and (3) that Herbst Management Trust was at all relevant
times a trust cognizable for Federal tax purposes. Nor did
Herbst Management Trust at any time provide any books, records,
or other information to respondent establishing the income
reported and the expense deductions claimed in Herbst Management
Trust’s 1996 and 1997 trust returns.
In the notice issued to Herbst Management Trust, respondent
determined, inter alia, that Herbst Management Trust is liable
for each of the taxable years 1996 and 1997 for the accuracy-
related penalty under section 6662(a).
Respondent has no record of Herbst Charitable Trust’s having
filed with respondent Form 990-PF, Return of Private Foundation
(Form 990-PF), for either of the taxable years 1996 and 1997.
Nor does respondent have a record of any other Federal tax
returns having been filed by Herbst Charitable Trust for those
years.
In response to a request by respondent for information with
respect to Herbst Charitable Trust, respondent was provided with
a copy of Form 990-PF for each of the taxable years 1996 and 1997
that showed Herbst Charitable Trust as the organization to which
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Last modified: May 25, 2011