AMC Trust, J.O. Haney, Jr., J.O. Haney, III and Patricia A. Haney Trustees, et al. - Page 12

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               Oliver & Co. did not report the asphalt business net income            
          on any return for 1996 through 1999.  On its Form 1041-A, U.S.              
          Information Return Trust Accumulation of Charitable Amounts, for            
          2000, dated September 25, 2002, Oliver & Co. reported income from           
          AMC Trust in the amount of $79,567, charitable deductions of                
          $73,567, and fiduciary fees of $6,000, leaving zero net income.             
          Oliver & Co. made no distribution to any charitable beneficiary             
          during the years in issue.                                                  
               The Oliver & Co. Form 1041-A was filed after examination of            
          petitioners’ returns commenced.  When Joey was contacted about              
          the examination of AMC Trust, he referred the revenue agent                 
          conducting the examination to J.O.  The Haneys sent to the                  
          revenue agent a document entitled “Notice of Expatriation and               
          Repatriation” dated March 11, 2002, in which they purported to              
          disavow their citizenship in the United States and “repatriate              
          back into the Texas Republic”.                                              
               The Internal Revenue Service commenced a proceeding to                 
          enforce a summons, and by order filed June 12, 2002, J.O. and               
          Joey were ordered to produce the records and materials requested            
          in the summons.  On July 1, 2002, the U.S. District Court for the           
          Western District of Texas, San Antonio Division, filed an order             
          finding, among other things, that J.O. and Joey “had submitted a            
          series of ‘tax protestor’ type responses to the summons and had             
          not complied with the May 9, 2002 Order.”  The Court order                  






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