Sue Taylor - Page 26

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         check to a third party.  See United States v. Allen, 551 F.2d                
         208, 212 (8th Cir. 1977).                                                    
              Respondent determined that petitioner provided personal real            
         estate marketing services to Krismon Buttes for which $70,000 was            
         paid and that this $70,000 was taxable to petitioner.  Petitioner            
         testified that marketing services were provided to Krismon Buttes            
         but denied providing them in her own name, stating they were                 
         provided through Speck.  Respondent sought to attribute all the              
         income of Speck to petitioner.  Petitioner, however, introduced              
         no evidence that Speck was an independent taxable entity rather              
         than a sham, assignee, or grantor trust as contended by                      
         respondent.  Where a sham transaction has no economic effect, it             
         will not be recognized for tax purposes.  Zmuda v. Commissioner,             
         731 F.2d 1417, 1421 (9th Cir. 1984) (citing Thompson v.                      
         Commissioner, 631 F.2d 642, 646 (9th Cir. 1980), affg. 66 T.C.               
         1024 (1976)), affg. 79 T.C. 714 (1982).                                      
              The address for Speck on National Land Bank’s 1999 Form                 
         1065, Schedule K-1, was the same as petitioner’s:  20 N. Gilbert             
         Road, Gilbert, Arizona 85234.  On National Land Bank’s amended               
         1999 Form 1065, the address for Speck on the attached Form 1065,             
         Schedule K-1 was changed to 5804 W. Vista Drive, #347, Glendale,             
         Arizona 85301.  Changing Speck’s address on the Form 1065,                   
         Schedule K-1 attached to National Land Bank’s 1999 amended Form              







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