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income tax returns distributions they received from the trusts.
The totality of the evidence, however, establishes that the
trusts Alsop established in May of 1992 were shams. The trusts
lacked economic substance, and they are not to be recognized for
Federal income tax purposes.
In light of our holding on the above issue, we need not
address an alternative argument made by respondent that under the
grantor trust rules Alsop should be taxed on the trust income.
With regard to the additions to tax and accuracy-related
penalties determined by respondent, Alsop makes no separate
argument, and we sustain respondent's determination of the
additions to tax and penalties.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011