NHUSS Trust, et al. - Page 11

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               In November of 2002, a second request was made by respondent           
          for petitioners’ books and records.                                         
               During respondent’s audit examination, petitioners did not             
          provide to respondent the requested books and records.                      
               On April 2, 2004, respondent mailed to petitioners separate            
          notices of deficiency for 1999 and 2000 with respect to NHUSS               
          Trust, RJ Pendergraft Trust, and In God We Trust.  In the notices           
          of deficiency, respondent determined, among other things, that in           
          1999 and 2000 various claimed deductions (e.g., deductions                  
          relating to purported distributions made between the trusts and             
          business expense deductions relating to the furniture business)             
          were not properly substantiated, that in 1999 and 2000 rental               
          income was not reported, and that in 1999 and 2000 various                  
          charitable deductions (including the charitable deduction for the           
          donation of the van) claimed by RJ Pendergraft Trust were not               
          properly substantiated.                                                     
               Also on April 2, 2004, respondent mailed to petitioners a              
          notice of deficiency for 1999 and 2000 relating to petitioners’             
          joint individual Federal income tax liabilities.  Respondent                
          determined, among other things, that for 1999 and 2000 the                  
          trusts’ income and expenses were to be collapsed into                       
          petitioners’ income and expenses and that for 2000 petitioners              

               4(...continued)                                                        
          treat petitioners’ liability for the negligence penalty with                
          respect to the tax adjustments relating to the three trusts as              
          still in issue.                                                             




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