Robert L. and Brenda J. Tarter - Page 3
- 3 -
Limited (BBT), a limited partnership. The partners of BBT were
petitioner and B & B Complex Trust, with petitioner having a
1-percent interest and B & B Complex Trust having a 99-percent
interest. By at least June 2001, B&B began to operate as BBT.
No Form 1065, U.S. Return of Partnership Income, was filed for
BBT for 2001. No Form 1041, U.S. Income Tax Return for Estates
and Trusts, was filed for the B & B Complex Trust for 2001.
Petitioner reported all claimed income and deductions of the
concrete business for 2001 as those of a sole proprietorship on
their Schedule C, Profit or Loss From Business.
A checking account for BBT, d.b.a. B&B, was opened on
May 17, 2001 (BBT account). At that time, a checking account
existed in the name of B&B and petitioners (B&B account).
Sometime after August or September 2001, operating expenses for
the concrete construction business were paid out of the BBT
account. After September 2001, funds represented by checks from
the BBT account were not funds that came from the B&B account.
B. Additional Entities
On September 15, 2000, petitioner set up the entity V & E
Leasing, Ltd., a California limited partnership (V&E Leasing).
The partners of V&E Leasing were petitioner and Granite Bay
Complex Trust. Upon formation of V&E Leasing, petitioner held a
1-percent interest, and Granite Bay Complex Estate Trust held a
99-percent interest. The depreciable vehicles and smaller
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: November 10, 2007