C. Earl Alsop - Page 3




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          a chiropractic practice.3  All references to petitioner are to              
          C. Earl Alsop.                                                              
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petitions were filed, Alsop and the named              
          trustee of petitioner's trusts resided in Utah.  Alsop was                  
          licensed in the State of Utah as a chiropractor.                            
               In May of 1992, Alsop established two trusts to which he               
          purported to transfer the assets and ownership of a chiropractic            
          business that he had operated for a number of years as a sole               
          proprietor.  Alsop, his wife, children, and grandchildren held              
          the legal and beneficial ownership interests in the trusts.  The            
          named trustee of the trusts was a personal friend of Alsop who              
          did not function as trustee of the trusts, who was not                      
          compensated, and who rendered no services to or for the trusts.             


          3    For each year, as a protective measure, respondent charged             
          the two trusts that Alsop established with income that respondent           
          also charged to Alsop individually.  If we sustain the tax                  
          deficiencies respondent determined against Alsop, we understand             
          that respondent will concede the tax deficiencies, additions to             
          tax, and accuracy-related penalties determined against the                  
          trusts.                                                                     




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