Larry L. Sather, Donor, et al. - Page 4




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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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