The Nis Family Trust - Page 6




                                                - 6 -                                                  
                  Hae-Rong and Lucy B. Ni                                                              
                  Respondent increased petitioners’ gross income by $439,230                           
            based on the alternative grounds that (1) the Nis Family Trust                             
            and the Nis Venture Trust (together, the Trusts) are shams with                            
            no economic substance, (2) the Trusts are grantor trusts, (3)                              
            under the assignment of income doctrine, petitioners are taxable                           
            on the income and deductions of the Trusts, or (4) if the Trusts                           
            are recognized for tax purposes, sections 652 or 662 function to                           
            increase the gross income of petitioners.  Respondent also made                            
            certain resultant adjustments and other adjustments that are not                           
            fully explained.                                                                           
            Pleadings                                                                                  
                  A separate petition in each of the consolidated cases was                            
            filed on May 21, 1999.  None of the petitions fully complied with                          
            our Rules, and, in each case, petitioner (petitioners in the case                          
            of Hae-Rong and Lucy B. Ni) was ordered by the Court to file an                            
            amended petition.  In each case, petitioner (or petitioners)                               
            filed an amended petition (together, the amended petitions)                                
            stating the following disagreement, and reasons therefor, with                             
            the adjustments set forth above (and accompanying penalty):                                
                  I disagree with all the adjustments and changes the                                  
                  Commissioner has made.  I do not believe that there was                              
                  any underlying liability due to a lack of                                            
                  consideration.  I have previously submitted facts with                               
                  the Internal Revenue Service “IRS” in support of my                                  
                  position in an effort to resolve the matter                                          
                  administratively.  The IRS failed or refused to                                      
                  consider those facts or my good faith effort to resolve                              





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