Richards Asset Mgmt. Trust, et al. - Page 2




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          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.                                                                   





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