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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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