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a chiropractic practice.3 All references to petitioner are to
C. Earl Alsop.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petitions were filed, Alsop and the named
trustee of petitioner's trusts resided in Utah. Alsop was
licensed in the State of Utah as a chiropractor.
In May of 1992, Alsop established two trusts to which he
purported to transfer the assets and ownership of a chiropractic
business that he had operated for a number of years as a sole
proprietor. Alsop, his wife, children, and grandchildren held
the legal and beneficial ownership interests in the trusts. The
named trustee of the trusts was a personal friend of Alsop who
did not function as trustee of the trusts, who was not
compensated, and who rendered no services to or for the trusts.
3 For each year, as a protective measure, respondent charged
the two trusts that Alsop established with income that respondent
also charged to Alsop individually. If we sustain the tax
deficiencies respondent determined against Alsop, we understand
that respondent will concede the tax deficiencies, additions to
tax, and accuracy-related penalties determined against the
trusts.
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