- 20 -
the accuracy-related penalty. On this record, there is similarly
no evidence that reasonable cause existed or that they were not
negligent when they filed their respective 1992 gift tax returns.
Accordingly, we sustain respondent's determinations against the
transferees, the Larry Trust, the John Trust, and the Duane
Trust, as to Kathy, Sandra, and Diane's liability for the
accuracy-related penalty.
In reaching our holdings herein, we have carefully
considered all arguments made by the parties for a contrary
result and, to the extent not discussed herein, find those
arguments irrelevant or without merit. To reflect the foregoing,
Decisions will be
entered for respondent with respect
to the deficiencies and for
petitioners with respect to the
penalties in docket Nos. 22141-97
and 22143-97; decisions will be
entered for respondent in docket
Nos. 22142-97, 22144-97, 469-98,
470-98, 471-98; and decisions will
be entered for petitioners in
docket Nos. 22145-97 and 22146-97.
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