Richards Asset Management Trust, et al. - Page 5

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          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 is           

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