- 3 - expenditures under section 263.3 We hold that the professional fees at issue were capital expenditures under section 263. FINDINGS OF FACT Most of the relevant facts have been stipulated and are so found.4 The stipulation of facts and supplemental stipulation of facts are incorporated herein by this reference. Petitioner resided in Gracemont, Oklahoma, at the time the petition in this case was filed. On January 18, 1990, petitioner's husband, S.G. "Red" Stevens (Mr. Stevens), as grantor, executed a Trust Agreement establishing a revocable inter vivos trust (the Trust) under the laws of the State of Oklahoma and designating Mr. Stevens as Trustee. Mr. Stevens’ property was transferred to, and thereafter owned by, the Trust. Pursuant to the terms of the Trust Agreement, all Trust income was either distributed to Mr. Stevens or added to the principal of the Trust during his lifetime. For Federal income tax purposes, the Trust was classified as a grantor trust. 3All section references are to the Internal Revenue Code as in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Monetary amounts are rounded to the nearest dollar. 4Our findings include a correction of a typographical error in par. 28 of the stipulation of facts; i.e., "1994" is changed to "1993".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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