- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011