- 2 - Respondent determined deficiencies in petitioner's 1993 and 1994 Federal income taxes in the amounts of $3,370 and $1,196, respectively. The issue for decision is whether certain miscellaneous itemized deductions attributable to a grantor trust are subject to section 67(a). FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner filed timely 1993 and 1994 Federal income tax returns. She resided in Omaha, Nebraska, at the time the petition was filed. Petitioner is a grantor and beneficiary of the Jay Newlin Trust (the trust). The trust was created on December 11, 1976, in order to preserve financial security for the grantors, more efficiently manage their investments, and gain financial advantages for the beneficiaries. Although certain restrictions apply to distributions of corpus, for Federal income tax purposes, the trust is what is commonly referred to as a grantor trust. See generally sections 671 through 679. During the years at issue, the trust corpus was valued at approximately $200 million, of which petitioner's interest was approximately 2.9 percent. The trust was administered by three trustees, none of whom had any expertise in the management of a large investment portfolio. In order to assist them in making financial and other investment decisions, the trustees retainedPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011