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Ms. Herbst filed Form 1040, U.S. Individual Income Tax
Return (return), for each of the taxable years 1996 and 1997.
During respondent’s examination of Ms. Herbst’s 1996 and 1997
returns and thereafter, Ms. Herbst provided no books, records, or
other information to respondent establishing the income reported
and the expense deductions claimed in those returns.
In the notice issued to Ms. Herbst, respondent determined,
inter alia, that Ms. Herbst is liable for each of the taxable
years 1996 and 1997 for the accuracy-related penalty under
section 6662(a).
Mr. Herbst filed a return for each of the taxable years 1996
and 1997. During respondent’s examination of Mr. Herbst’s 1996
and 1997 returns and thereafter, Mr. Herbst provided no books,
records, or other information to respondent establishing the
income reported and the expense deductions claimed in those
returns.
In the notice that respondent issued to Mr. Herbst, respon-
dent determined, inter alia, that Mr. Herbst is liable for each
of the taxable years 1996 and 1997 for the accuracy-related
penalty under section 6662(a).
James Binge (Mr. Binge) was the return preparer for each of
Herbst Management Trust’s 1996 and 1997 trust returns, each of
Ms. Herbst’s 1996 and 1997 returns, and each of Mr. Herbst’s 1996
and 1997 returns. Mr. Binge was also listed as the return
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Last modified: May 25, 2011