- 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
Last modified: May 25, 2011