R. Scot Stokes - Page 9




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          the grantor trust rules, petitioner should be taxed on gain from            
          sale of the pizza business.                                                 
               With regard to the accuracy-related penalty determined by              
          respondent, petitioner makes no separate argument, and we sustain           
          respondent's determination of the accuracy-related penalty.                 
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

































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