- 4 -
Petitioner described TTS as an educational program that
provided services enabling participants to “learn how to read
& study the law, interpret the IRS’ codes and publications, and
understand the ‘sophisticated’ manner in which Trustees should
carry on business and live within the framework of Complex
Trusts.” The “complex trusts” to which petitioner referred
included the trusts that petitioner testified NTS would promote
and package together with an allegedly charitable trust to
provide tax benefits. Petitioner spoke at NTS’s conferences in
1998, 1999, and 2000 and provided consultation services to the
principals4 of NTS. Petitioner continued to engage in his DSG
consulting business during 1997 through 2000 and did not at any
time file any Federal income tax returns for DSG.5
Prior Taxable Years: 1987 Through 1992 and 1994 Through 1996
Respondent’s agent, Jacob Riley (Agent Riley), beginning in
1997 conducted an examination of petitioner’s 1994 through 1996
taxable years. He typically reviewed tax returns in the abusive
promotions and abusive returns area,6 and in connection with this
work, he determined that petitioner had not yet filed Federal tax
4 Petitioner testified that part of these consultation
services entailed clarifying issues in a dispute between NTS
principals Rick Prescott and Roy Fritts.
5 The parties stipulated that DSG is a disregarded entity
for Federal income tax purposes.
6 Petitioner and Agent Riley first met when petitioner
represented a trust during the audit of another taxpayer.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011