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