Kenneth W. Stejskal, Sr. and Jane Stejskal, et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  Respondent determined deficiencies in and               
          additions to tax with respect to petitioners’ Federal income tax            
          for 1999 as follows:                                                        
                                             Additions to tax/penalties               
                                             Internal Revenue Code                    
          Docket No.       Deficiencies   Sec. 6651(a)(1)     Sec. 6662(a)            
          2275-04          $112,919     $16,937.85          $22,583.80                
          2276-04          347,030           52,054.50      69,406.00                 
          2277-04          374,189           56,128.35      74,837.80                 
          2278-04          373,621           56,043.15      74,724.20                 
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  The deficiencies included “whipsaw” determinations              
          against petitioner trusts in the event that the validity of the             
          trusts was sustained by the Court.  However, in a stipulation of            
          settled issues, the parties agreed:                                         
                    1.  Stejskal Enterprises Trust, Bioactive Kansas                  
               Trust, and Total Health Center Trust should be                         
               disregarded for tax purposes because the trusts were                   
               grantor trusts, lacked economic substance, or were                     
               assigned income attributable to Petitioners Kenneth W.                 
               Stejskal, Sr. and Jane Stejskal.                                       
                                                                                     
                        *     *     *     *     *     *     *                         
                    3.  All income reported by Stejskal Enterprises                   
               Trust, Bioactive Kansas Trust, and Total Health Center                 
               Trust is properly reportable by Petitioners Kenneth W.                 
               Stejskal, Sr. and Jane Stejskal on their Individual                    
               Income Tax Return, Form 1040, on Schedule C, Profit or                 
               Loss from Business.                                                    






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