C. Earl Alsop - Page 2




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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               SWIFT, Judge:  In these consolidated cases, respondent                 
          determined deficiencies in petitioners' Federal income taxes,               
          additions to tax, and accuracy-related penalties as follows:                


                                                       Accuracy-Related               
                              Additions to Tax          Penalty                       
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6654      Sec. 6662(a)           
          C. Earl Alsop                                                               
          1991      $38,259   $ 9,565         $2,202   --                             
          1992      38,185    9,546          1,665     --                             
          1993      54,933    --        --             $10,987                        
          1994      63,709         --   --             12,742                         
          FCHC Trust                                                                  
                                                                                     
          1992      $34,600   $ 8,650         --       $ 6,920                        
          1993      57,203    14,301         --             11,441                    
          1994      62,538    --              --            12,508                    
          Mountain Meadows Trust                                                      
          1993      $57,203   $14,301            --    $11,441                        
          1994      62,538    --             --            12,508                    

               After settlement, the primary issue for decision is                    
          whether two trusts2 that petitioner established are to be                   
          disregarded for Federal income tax purposes and whether                     
          petitioner C. Earl Alsop (Alsop) is to be charged with income of            





          2    By the mere use of the term “trusts” we intend no                      
          implication as to whether the trusts should be recognized for               
          Federal income tax purposes.                                                




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