Jeffrey Michael Steingold - Page 2




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          Internal Revenue Code (Code) in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               The issues for decision are whether:  (1) The notice of                
          deficiency relating to petitioner’s 1993 return was timely; (2)             
          petitioner is liable for tax relating to undistributed trust                
          income; and (3) petitioner is liable for additions to tax for               
          failing to file his 1993 and 1994 returns in a timely manner.               
                                  FINDINGS OF FACT                                    
               Petitioner resided in Ashland, Virginia, at the time the               
          petition was filed.  Petitioner filed his 1993 and 1994 returns             
          on September 23, 1994, and December 15, 1995, respectively.  The            
          notice of deficiency was sent to petitioner on October 29, 1998.            
               Petitioner was a beneficiary of a trust which provided that            
          he receive “the entire net income of his respective share, in               
          convenient installments.”  The trustee had the discretion to                
          distribute principal.  No distributions were made from the trust            
          in 1993 or 1994.  An order of the Virginia Beach Chancery Court             
          (State Court), dated February 17, 1994, required the trustee to             
          retain all trust income.  Subsequently, the State Court                     
          terminated the trust and distributed petitioner’s share to                  
          satisfy his obligations.                                                    










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