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accounts in 1997. He used a signature stamp bearing the name
“Robert Hogue” to sign checks on those bank accounts in 1997-
2001.
Petitioners’ trusts filed Forms 1041, U.S. Fiduciary Income
Tax Return, for 1997. Each trust reported income and expenses
from one of the nursing care facilities on its 1997 return. The
trusts reported the following amounts of income for 1997:
Trust ` Gross Receipts Interest
Residential $334,048 $196
Rancho $303,628 $219
Sunshine $233,694 0
Home Health $350,310 $453
3. Petitioners and Their Residences
Sometime before 1997, petitioners owned and lived in a
residence in Palo Cedro, California (the Palo Cedro residence).
They transferred title to that residence to Douglas Carpa and
Robert L. Talbot, trustees of Ranch Holding Trust, on a date not
contained in the record. Robert Hogue was the purported trustee
of Ranch Holding Trust at the end of 1997. Petitioner used funds
from Sunshine’s bank account to pay the property taxes on the
Palo Cedro residence in April 1997.
Property taxes on the Palo Cedro residence were paid in
December 1997 with funds from Home Health’s account and in April
1999 with funds from Residential’s account.
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Last modified: May 25, 2011