Leon L. Zachman and Estate of Ione Zachman - Page 18




                                       - 18 -                                         
         or penalties.  We have sustained respondent’s determination that             
         petitioners understated their Federal income tax liability for               
         taxable years 1987, 1988, and 1989.  Accordingly, petitioners’               
         argument must fail.                                                          
              Petitioners have not established that they used reasonable              
         care in ascertaining their income tax liability for these years.             
         They have not shown that they reasonably relied on a competent               
         professional adviser independent of those persons who were                   
         involved in marketing these abusive trusts.  We sustain                      
         respondent’s determinations on this issue.                                   
              To reflect the foregoing,                                               

                                            Decision will be entered                  
                                       for respondent.                                
























Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  

Last modified: May 25, 2011