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2. Whether the Larry Trust, the John Trust, and the Duane
Trust are liable as transferees for the unpaid 1992 gift tax and
penalties owing by Kathy, Sandra, and Diane. We hold they are.
3. Whether Larry, Kathy, John, Sandra, and Diane are liable
for the accuracy-related penalty under section 6662(a) as
determined by respondent. We hold Larry and John are not and
Kathy and Sandra are.
Section references are to the applicable versions of the
Internal Revenue Code. 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.
The stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference. Sathers, Inc. (Sathers),
is a candy distribution business that has been in business since
1946. Since its inception, Sathers has been owned directly or
indirectly by the Sather family. For at least the past 10 years,
Neil Kaplan (Kaplan), a certified public accountant, has served
as accountant for Sathers, and Nancy Bender-Keller (Bender-
Keller), an attorney, has been its counsel. Kaplan worked as an
accountant for more than 30 years. His experience includes
employment at the Internal Revenue Service, and he was previously
a partner in the tax department of Deloitte & Touche.
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