Forest L. Buckmaster - Page 2

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            related penalty under section 6662(a) for substantial                                        
            understatement of income tax.  Respondent reflected these                                    
            determinations in a notice of deficiency issued to petitioner on                             
            December 18, 1995.                                                                           
                  Following respondent's concession of the addition to tax                               
            under section 6654(a), we must determine the following issues:                               
                  1.  Whether petitioner's gross income includes his personal                            
            service income paid to a trust entitled Ideal Management.2  We                               
            hold it does.                                                                                
                  2.  Whether petitioner is liable for the accuracy-related                              
            penalty determined by respondent.  We hold he is.                                            
                  3.  Whether petitioner is liable for a penalty under section                           
            6673(a)(1).  We hold he is liable for a penalty of $5,000.                                   
                  Unless otherwise indicated, section references are to the                              
            Internal Revenue Code in effect for the year in issue.  Rule                                 
            references are to the Tax Court Rules of Practice and Procedure.                             
            Dollar amounts are rounded to the nearest dollar.                                            
                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.                               
            The stipulated facts and exhibits submitted therewith are                                    
            incorporated herein by this reference.  Petitioner resided in                                
            San Diego, California, when he petitioned the Court.  He filed a                             

                  2 Although we use the word "trust" to refer to Ideal                                   
            Management, we do not mean to suggest that Ideal Management is a                             
            trust for Federal income tax purposes.  As discussed below, we                               
            conclude it is not.  We use the word "trust" merely for                                      

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