- 2 - reconsideration) of our Memorandum Opinion in these cases set forth in T.C. Memo. 2002-74 (Richards I). We shall deny that motion. We begin by setting forth the background pertinent to this Supplemental Memorandum Opinion, which includes not only the background set forth in Richards I that we incorporate herein by this reference, but also certain other matters that the record in these cases establishes and/or that the parties do not dispute. Background Richards Asset Management Trust (Richards Management Trust)2 filed Form 1041, U.S. Income Tax Return for Estates and Trusts (trust return), for each of the taxable years 1996 and 1997. In separate Schedules K-1, Beneficiary’s Share of Income, Deduc- tions, Credits, etc., that Richards Management Trust included with each of its 1996 and 1997 trust returns, Richards Management Trust showed Everett D. Richards (Mr. Richards) and Richards Charitable Trust as beneficiaries and Mr. Richards as the fidu- ciary of Richards Management Trust. In each of its 1996 and 1997 trust returns, Richards Manage- ment Trust deducted depreciation with respect to certain personal 2When referring in this Supplemental Memorandum Opinion to Richards Asset Management Trust, Richards Management Trust, and Richards Charitable Trust, our use of the word “Trust” and any similar words is for convenience only and is not intended to convey any meaning or have any significance for Federal tax purposes.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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