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authorized to act on behalf of Richards Charitable Trust, and
(3) that Richards Charitable Trust was at all relevant times a
trust cognizable for Federal tax purposes. Nor did Richards
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 copy of Form 990-PF for the
taxable year 1997 that was provided to respondent during respon-
dent’s examination of Richards Charitable Trust in response to
respondent’s request for information with respect to Richards
Charitable Trust and that showed Richards Charitable Trust as the
organization to which such form pertained.
In the notice issued to Richards Charitable Trust, respon-
dent determined, inter alia, that Richards Charitable Trust is
liable for each of the taxable years 1996 and 1997 for the
addition to tax under section 6651(a)(1).
Joy A. Richards and Mr. Richards jointly filed Form 1040,
U.S. Individual Income Tax Return (return), for the taxable year
1996, and Mr. Richards filed a return for 1997. During respon-
dent’s examination of those 1996 and 1997 returns and thereafter,
no books, records, or other information was provided to respon-
dent establishing the income reported and the expense deductions
claimed in those returns.
In the notice issued to Mr. Richards with respect to the
taxable year 1996, respondent determined, inter alia, that he is
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