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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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Last modified: May 25, 2011