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On January 13, 2003, a timely petition for redetermination
challenging the notice of deficiency was filed in this Court on
behalf of the McKenzie Trust. The caption of the petition
contained the name of the trust and its fiduciary, and the
petition was signed by Joe Alfred Izen, Jr., as attorney for the
trust.
On October 20, 2003, respondent filed a written motion to
dismiss the petition filed by the McKenzie Trust for lack of
jurisdiction, which we address in the opinion that follows.
IV. The Gouveias’ Income Tax Returns for 1995, 1996, 1997, and
1998
On their income tax returns for the years at issue, the
Gouveias reported the following amounts:
Schedule C Schedule E Total gross
Year Interest net profit/loss net inc./loss income
1995 $3,724 -0- $3,224 $38,458
1996 3,026 $13,224 3,712 21,807
1997 1,568 25,026 3,261 31,725
1998 1,132 30,208 1,854 35,895
The following items of income from the Pago Trust and/or the
McKenzie Trust were included in the above amounts:
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