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that respondent determined for the taxable year 1996 in the
notice issued to Everett D. Richards (Mr. Richards)4 in the case
at docket No. 10765-00; (3) the accuracy-related penalty under
section 6662(a) for the taxable year 1997 that respondent deter-
mined in the notice issued to Mr. Richards in the case at docket
No. 10766-00; and (4) the addition to tax under section
6651(a)(1) for each of the taxable years 1996 and 1997 that
respondent determined in the notice issued to Richards Charitable
Trust5 in the case at docket No. 10767-00.
Background
The record establishes and/or the parties do not dispute the
following:
At the time the respective petitions in these cases were
filed, Richards Management Trust, Mr. Richards, and Richards
Charitable Trust listed in those petitions the same address in
Canton, Ohio.
Richards Management Trust filed Form 1041, U.S. Income Tax
4In the case at docket No. 10765-00, respondent issued the
notice to Mr. Richards and Joy A. Richards, deceased. Although
the petition in that case was filed in the name of Mr. Richards
and Joy A. Richards, deceased, on Oct. 12, 2001, the Court
dismissed the case for lack of jurisdiction as to Joy A. Rich-
ards, deceased. For convenience, we shall refer hereinafter to
the notice issued with respect to the case at docket No. 10765-00
as the notice issued to Mr. Richards.
5When referring in this Opinion to Richards Charitable
Trust, our use of the word “Trust” and any similar words are for
convenience only and is not intended to convey any meaning or
have any significance for Federal tax purposes.
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