Homer L. Richardson - Page 20

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          utilities were all attributable in significant part to the                  
          Quailwoods Drive residence.  The insurance expense also included            
          a component for life insurance for Mr. Richardson, and the                  
          medical expenses pertained to healthcare for petitioners.                   
               Mr. Richardson signed each of the Forms 1041 as a fiduciary            
          of HGAMC.  An attachment to the 1996 return contained the                   
          following:  “The Fiduciary of this Trust hereby elects to treat             
          contributions made this year and the next subsequent tax year as            
          paid during this tax year as provided for by IRC Secion [sic] 642           
          (c)(1)”.  A substantially identical statement was attached to the           
          1997 return.  The attachments further provided that the                     
          contributions for the next year to be treated as paid during 1996           
          and 1997 were $259,880 and $51,299, respectively.                           
               Concerning HGRCT, the Form 990-PF for 1996 reflected no                
          revenue (including contributions), expenditures, assets, or                 
          liabilities of any kind.  The return listed both petitioners as             
          trustees and indicated that each devoted 2 hours per week to his            
          or her position.  Mr. Richardson executed the return as a                   
          trustee.                                                                    
               The Form 990-PF for 1997 showed contributions received of              
          $259,880, interest income of $85, operating and administrative              
          expenses of $198, and contributions made of $12,994.  Resultant             
          excess of revenue over expenses and disbursements, as well as net           
          assets, was $246,773.  Petitioners were again listed as the                 






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