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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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Last modified: May 25, 2011