- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011