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assets of Mr. Richards, including Mr. Richards’ personal resi-
dence that he had transferred to Richards Management Trust at a
time that is not disclosed by the record. Richards Management
Trust also deducted other amounts in its 1996 and 1997 trust
returns with respect to personal expenses of Mr. Richards.
During respondent’s examination of Richards Management
Trust’s 1996 and 1997 trust returns and thereafter, no books,
records, or other information was provided to respondent estab-
lishing (1) the jurisdiction under the laws of which Richards
Management Trust was purportedly organized, (2) the person who is
authorized to act on behalf of Richards Management Trust, and
(3) that Richards Management Trust was at all relevant times a
trust cognizable for Federal tax purposes. Nor did Richards
Management Trust at any time provide any books, records, or other
information to respondent establishing the income reported and
the expense deductions claimed in Richards Management Trust’s
1996 and 1997 trust returns.
Respondent has no record of Richards Charitable Trust’s
having filed with respondent Form 990-PF, Return of Private
Foundation (Form 990-PF), for either of the taxable years 1996
and 1997. Nor does respondent have a record of any other Federal
tax returns having been filed by Richards Charitable Trust for
those years.
In response to a request by respondent for information with
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Last modified: May 25, 2011