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The issues for decision are:3
(1) Whether the petitions filed in the names of the Pago
and/or McKenzie Trusts should be dismissed for lack of
jurisdiction;
(2) whether the Pago and/or McKenzie Trusts should be
disregarded for Federal income tax purposes;
(3) even if the Pago and/or McKenzie Trusts are not
disregarded for Federal income tax purposes, whether the net
income of the rental real estate business, allegedly owned by the
Pago Trust, and the automobile restoration business, allegedly
owned by the McKenzie Trust, must be reported by Greg Gouveia
(petitioner) and Carol Gouveia (collectively referred to as the
Gouveias) on their Federal income tax returns for the years at
issue;
(4) whether the notice of deficiency for the Gouveias’ 1995
and 1996 taxable years was timely;
(5) if the Pago and McKenzie Trusts are respected for
Federal income tax purposes, whether either trust is entitled to
deductions for income distributions, management fees, or
fiduciary fees; and
3The only other issues raised in the notices of deficiency
and petitions are computational.
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Last modified: May 25, 2011