Herbst Asset Mgmt. Trust, et al. - Page 4




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          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            
          each such form pertained.  However, as discussed above, respon-             
          dent has no record that Herbst Charitable Trust filed with                  
          respondent Forms 990-PF for the taxable years 1996 and 1997.                
               During respondent’s examination of Herbst Charitable Trust’s           
          taxable years 1996 and 1997 and thereafter, no books, records, or           
          other information was provided to respondent establishing (1) the           
          jurisdiction under the laws of which Herbst Charitable Trust was            
          purportedly organized, (2) the person who is authorized to act on           
          behalf of Herbst Charitable Trust, and (3) that Herbst Charitable           
          Trust was at all relevant times a trust cognizable for Federal              
          tax purposes.  Nor did Herbst Charitable Trust at any time                  
          provide any books, records, or other information to respondent              
          establishing the income shown and the expense deductions claimed            
          in the copies of Forms 990-PF for the taxable years 1996 and 1997           
          that were provided to respondent during respondent’s examination            






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