-3- not all of petitioners’ personal assets to Re-Cap Trust. Neither Hill nor his wife had beforehand consulted a competent professional concerning the Federal income tax consequences of Re-Cap Trust. As to the subject year, Re-Cap Trust filed a 1999 Form 1041, U.S. Income Tax Return for Estates and Trusts, that reported total income of $332,520 and total deductions of $330,818. With the exception of interest income of $435, the total income was all attributable to commissions for realtor services performed by Hill. The deductions claimed by Re-Cap Trust were in part for petitioners’ personal expenses, including many of their personal living expenses. Re-Cap Trust reported on this Form 1041 that its 1999 total tax was $255. Re-Cap Trust also claimed on that form a deduction for gifts and donations totaling $21,439. The record does not identify the individual amounts which go into the $21,439.1 Nor does the record include a “written acknowledgment”, sec. 170(f)(8), from any recipient who received a payment of $250 or more. 1 Although petitioners have referred to various purported charities and note that the record contains checks drawn on the checking account of Re-Cap Trust, we are unable to reconcile our total of the checks payable to those referenced “charities” to the $21,439 claimed by petitioners.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011