Larry L. Sather, Donor, et al. - Page 20




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          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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