Richards Asset Management Trust, et al. - Page 6

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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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