- 20 - 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 thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011