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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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