T.C. Memo. 1997-180
UNITED STATES TAX COURT
JAMES C. ESTRADA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6241-95. Filed April 15, 1997.
P created two "trusts". P and O then formed a
partnership (NAA) to perform nurse anesthetic services,
listing O and one of the "trusts", T, as partners. P
and O were the only people who performed services on
behalf of NAA.
Held: P is taxed on any income transferred to the
"trust".
Held, further, P is liable for additions to tax
under sec. 6651(a), I.R.C.
Held, further, P is liable for additions to tax
under sec. 6654(a), I.R.C.
Jeffrey A. Dickstein, for petitioner.
Andrew H. Lee, for respondent.
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