- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011