Homer L. Richardson - Page 21

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          trustees with an average of 2 hours apiece per week devoted to              
          their work for HGRCT, and Mr. Richardson again signed the return            
          as trustee.                                                                 
          Examination                                                                 
               On July 13, 1999, the IRS mailed to each petitioner, with              
          respect to the 1996 and 1997 taxable years, a letter advising as            
          follows:                                                                    
                    The Internal Revenue Service has information                      
               indicating that you may be involved in a trust                         
               arrangement used for tax avoidance purposes.  This                     
               letter is to inform you of the Internal Revenue                        
               Service’s position regarding abusive trust                             
               arrangements.  It is the government’s position that                    
               trusts will be disregarded for tax purposes and the                    
               income will be taxed to the person who controls the                    
               trust, if the trust lacks economic substance or has                    
               been structured for tax avoidance purposes.                            
                    In addition to disregarding the trust entity, the                 
               government may pursue civil and/or criminal penalties                  
               against taxpayers and promoters who attempt to use                     
               trusts to avoid income tax liability.                                  
                    If you are a participant in a trust scheme that                   
               has any of the abusive elements described in Notice 97-                
               24 attached, you have the option of correcting your                    
               income tax filings to reflect the proper income and                    
               expenses on your personal, corporate and partnership                   
               returns, as applicable.  Any trust returns previously                  
               filed should also be corrected to eliminate income and                 
               expenses reported.                                                     
          The letters went on to request that petitioners provide                     
          documentation with respect to the trust (presumably HGAMC) in the           
          event that they determined that their position was appropriate              
          under Notice 97-24, 1997-1 C.B. 409.                                        







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