- 5 - the expense deductions claimed in Richards Management Trust’s 1996 and 1997 trust returns. In the notice issued to Richards Management Trust, respon- dent determined, inter alia, that Richards 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 Richards 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 Richards Charitable Trust for those years. In response to a request by respondent for information with respect to Richards Charitable Trust, respondent was provided with a copy of Form 990-PF for the taxable year 1997 that showed Richards Charitable Trust as the organization to which such form pertained. However, as discussed above, respondent has no record that Richards Charitable Trust filed with respondent Form 990-PF for the taxable year 1997. During respondent’s examination of Richards Charitable Trust’s taxable years 1996 and 1997 and thereafter, no books, records, or other information was provided to respondent estab- lishing (1) the jurisdiction under the laws of which Richards Charitable Trust was purportedly organized, (2) the person who isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011