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Alexion Trust
Alexion Trust is a trust created by the J. Shirleys.
Alexion Trust was created on September 1, 1994. In 1995, Caralan
Trust was the sole beneficiary of Alexion Trust.
In 1995, one or the other, or both, of the J. Shirleys had
signatory authority over Alexion Trust’s bank accounts. The
J. Shirleys used such bank accounts to pay certain of their
personal expenses in 1995.
For 1995, Joseph Shirley made a return of Federal income tax
for Alexion Trust on Form 1041, U.S. Income Tax Return for
Estates and Trusts (the Alexion Trust 1995 return). He signed
that return as a fiduciary. In that return, Alexion Trust
reported gross receipts of $179,791 from an activity described as
computer consulting. It reported various expenses related to
that activity, including $42,000 claimed for the rental of
business property. It reported no expense for wages. After
deducting expenses totaling $78,260, it reported a net profit of
$101,531 from such activity. From that reported net profit, it
deducted a claimed charitable contribution of $94 and reported
“Adjusted total income” of $101,437. From such adjusted taxable
income, it deducted $101,437 on account of an income distribution
to Caralan Trust. After taking into account a deduction of $100
for a personal exemption, it reported a loss of $100 and no
income tax due.
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