James C. Estrada - Page 1

                                 T.C. Memo. 1997-180                                  


                               UNITED STATES TAX COURT                                


                           JAMES C. ESTRADA, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6241-95.              Filed April 15, 1997.                 


                    P created two "trusts".  P and O then formed a                    
               partnership (NAA) to perform nurse anesthetic services,                
               listing O and one of the "trusts", T, as partners.  P                  
               and O were the only people who performed services on                   
               behalf of NAA.                                                         
                    Held:  P is taxed on any income transferred to the                
               "trust".                                                               
                    Held, further, P is liable for additions to tax                   
               under sec. 6651(a), I.R.C.                                             
                    Held, further, P is liable for additions to tax                   
               under sec. 6654(a), I.R.C.                                             

               Jeffrey A. Dickstein, for petitioner.                                  
               Andrew H. Lee, for respondent.                                         







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