T.C. Memo. 2001-241
UNITED STATES TAX COURT
CARALAN TRUST, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 10151-99, 10152-99, Filed September 17, 2001.
10153-99, 17074-99,
17075-99, 17076-99.
R attributed to P1 and P2, both joint return
filers, various items with respect to certain trusts,
P3, P4, P5, and P6, on the grounds that such trusts
were either shams or grantor trusts, or on the ground
that the assignment of income doctrine applied. R also
claims that P2 failed to report certain nontrust items
of income. R determined a sec. 6662(a), I.R.C.,
accuracy-related penalty against each P. At trial, R
1 Cases of the following petitioners are consolidated
herewith: Alexion Trust, docket No. 10152-99; Joseph and Frances
Shirley, docket No. 10153-99; Curtis E. and April L. Shirley,
docket No. 17074-99; C E Shirley Trust, Marcia Doerr, Trustee,
docket No. 17075-99; and Congo Trust, Marcia Doerr, Trustee,
docket No. 17076-99.
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