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agreement. Some years, petitioner left a portion of the trust
income with the trust assets. This undistributed net income,
which amounted to approximately $2.2 million by January 1, 2000,
was noted in the trust’s books and records. Although petitioner
intentionally did not pay himself the trust’s net income, he
never intended to relinquish his claim to this undistributed
income. Petitioners reported all of the trust’s income (both
distributed and undistributed) on their tax returns in the
respective years the trust earned the income.
The trust and petitioner treated certain transactions
involving the trust’s donations to charity as deemed
distributions to petitioner over the years. A financial
spreadsheet prepared by the trust’s certified public accountant
(CPA) indicates that the trust treated $46,465 as deemed
distributions to petitioner during 2000.
Land in the Trust
The trust acquired significant real estate over the years.
The trust acquired approximately 3,000 acres of land in Tunica
County, Mississippi, which we refer to as the Duck Lake property.
The trust also acquired several thousand additional acres of
contiguous property in Mississippi, north of the Duck Lake
property and between the Mississippi River and Tunica Cutoff
Lake. This property north of the Duck Lake property is referred
to as the Riverbend/M’hoons Bend property.
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Last modified: May 25, 2011