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Robert A. and Colleen L. Lund
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $ 504,031 $100,806
1995 945,507 189,101
1996 1,292,331 258,466
Zero Gee Enterprises Trust
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $ 495,582 $ 99,116
1995 908,550 181,710
1996 1,259,332 251,866
After settlement of some issues, the primary issue for
decision involves whether a trust1 petitioner established lacks
economic substance and should be disregarded for Federal income
tax purposes.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. References to petitioner in the singular are to
Robert A. Lund.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petitions were filed, petitioner and Colleen
Lund resided in Albany, Oregon, and the principal place of
1 By use of the terms “trust”, “trustee”, “beneficiary”, and
other related terms, we intend no implication as to the validity
of the trust involved in these cases.
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Last modified: May 25, 2011