Janice L. Morris - Page 38

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          distribution by a trust to a beneficiary is generally taxable               
          only to the extent of distributable net income.  See secs. 652,             
          662.                                                                        
               Under the circumstances presented here, we do not think                
          that it was unreasonable that petitioner did not ask Mr. Morris             
          about the tax consequences of the distributions by and/or the               
          operations of Accu-Data, Trust 768, Meadows, and MCIC, but                  
          instead relied on him to prepare correctly the joint returns in             
          question and the returns that he prepared for the entities that             
          he controlled.                                                              
               Additional circumstances that we believe justify peti-                 
          tioner's not inquiring about the possibility of substantial                 
          understatements in the joint returns in question are that, in               
          addition to her responsibilities for handling the family finances           
          during the years at issue, petitioner also was preoccupied during           
          those years as a homemaker, mother, and part-time student.  She             
          was taking classes at either Parkland College or the University             
          of Illinois until the spring of 1989.  At that time, she withdrew           
          from college because it was consuming too much of her time during           
          a period when she wanted and believed that she had to, and did in           
          fact, devote more time to her children who were experiencing                
          serious problems.                                                           
               It is also significant to us that there is no suggestion in            
          the record in this case that petitioner was living lavishly                 
          during the years at issue or that her living conditions signifi-            




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