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establishment of trusts has no real economic effect, the
substance of the transactions involving the trusts will control
over the form. See Zmuda v. Commissioner, 731 F.2d 1417,
1420-1421 (9th Cir. 1984), affg. 79 T.C. 714, 719 (1982);
Markosian v. Commissioner, 73 T.C. 1235, 1241 (1980); Christal v.
Commissioner, T.C. Memo. 1998-255.
This Court and the U.S. Courts of Appeals have long rejected
attempts similar to Alsop’s herein to avoid taxation by the use
of abusive family trusts. See Holman v. United States, supra;
Hanson v. Commissioner, 696 F.2d 1232 (9th Cir. 1983), affg. per
curiam T.C. Memo. 1981-675; Schulz v. Commissioner, 686 F.2d 490
(7th Cir. 1982), affg. T.C. Memo. 1980-568; Vnuk v. Commissioner,
621 F.2d 1318 (8th Cir. 1980), affg. T.C. Memo. 1979-164; Vercio
v. Commissioner, 73 T.C. 1246 (1980); Wesenberg v. Commissioner,
69 T.C. 1005 (1978); Buckmaster v. Commissioner, T.C. Memo. 1997-
236. Such trusts are treated as lacking in economic substance
and as constituting a nullity for Federal income tax purposes.
See Hanson v. Commissioner, supra; Markosian v. Commissioner,
supra; Wenz v. Commissioner, T.C. Memo. 1995-277.
Attempts by chiropractors, in particular, who have sought to
avoid taxation on income relating to their chiropractic practices
by assigning or attributing income from the practices to "family
trusts" have been rejected. See Sandvall v. Commissioner,
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