-4- of PERJ Trust. They stated further that PERJ Trust is revocable at their discretion. On July 25, 1995, petitioners signed a “Uniform Residential Loan Application”. In the loan application, Mr. Nichols stated that he had been self-employed for 19 years as the owner-operator of a sweeping business doing business as Clean Sweep Maintenance. Petitioners also listed their personal checking and savings accounts. Those same accounts were the bank accounts of CSM Trust, JREP Trust, and PERJ Trust. During 1997 and 1998, petitioners were the only persons who had signatory authority over those bank accounts. CSM Trust filed partnership returns for 1997 and 1998.3 PERJ Trust was indicated as a partner holding a 99-percent profit interest in CSM Trust, and Ms. Nichols was said to be a partner holding a 1-percent profit interest in CSM Trust. Those returns were filed under the same employer identification number as had been used on the trust income tax returns filed in the name of CSM Trust for taxable years before 1997. On their 1997 and 1998 Federal income tax returns, petitioners understated their interest income by $25 and $45, respectively. Petitioners also did not report Social Security 3 The record does not indicate why CSM Trust filed partnership returns for those years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011