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following taxpayers, in the following amounts, for the 1995
taxable (calendar) year of each:
Sec. 6662(a)
Docket No. Taxpayer(s) Deficiency Penalty
10151-99 Caralan Trust $55,935 $11,187
10152-99 Alexion Trust 70,329 14,066
10153-99 Joseph & Frances 77,483 15,497
Shirley
17074-99 Curtis E. & April 25,306 5,061
L. Shirley
17075-99 C E Shirley Trust 25,249 5,050
17076-99 Congo Trust 3,978 796
These cases are related in that, under various theories,
respondent believes that there is an identity between Caralan
Trust, Alexion Trust, and Joseph and Frances Shirley (sometimes,
the J. Shirleys) and an identity between C E Shirley Trust, Congo
Trust, and Curtis E. and April L. Shirley (sometimes, the
C. Shirleys). The J. Shirleys are the parents of Curtis E.
Shirley. Respondent would attribute the income of the various
trusts to the Shirleys identified by respondent with such trusts.
At the conclusion of the trial in these cases, respondent
moved that the Court impose penalties under section 6673(a)(1),
which provides penalties for procedures instituted primarily for
delay and for other reasons.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. For convenience, monetary amounts have been rounded
to the nearest dollar amount.
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Last modified: May 25, 2011