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liable for that taxable year for the accuracy-related penalty
under section 6662(a). In the notice issued to Mr. Richards with
respect to the taxable year 1997, respondent determined, inter
alia, that he is liable for that taxable year for the accuracy-
related penalty under section 6662(a).
James Binge (Mr. Binge) was the return preparer for each of
Richards Management Trust’s 1996 and 1997 trust returns, Mr.
Richards and Joy A. Richards’ 1996 return, and Mr. Richards’ 1997
return. Mr. Binge was also listed as the return preparer for
Richards Charitable Trust’s Form 990-PF for the taxable year 1997
that was provided to respondent during respondent’s examination
of Richards Charitable Trust but that respondent has no record of
having been filed with respondent. Respondent has identified Mr.
Binge as an individual involved with purported trusts used for
tax avoidance purposes.
On August 31, 2001, respondent filed separate motions to
compel answers to interrogatories and to compel production of
documents in each of the cases at docket Nos. 10765-00 and 10766-
00. On September 19, 2001, the Court granted each of those
motions. Mr. Richards did not answer respondent’s interrogato-
ries or produce the documents requested by respondent, as ordered
by the Court on September 19, 2001.
On October 2, 2001, Richards Management Trust, Mr. Richards,
and Richards Charitable Trust filed a joint motion to continue
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Last modified: May 25, 2011