- 12 -
Throughout the years at issue, the jewelry business operated
at the same location and in the same manner as it had before its
transfer to the CCJT, and petitioner continued to work as a
jeweler for, and manager of, the jewelry business.
III. Tax Returns
A. 1995
The CCJT filed a timely Form 1041, U.S. Income Tax Return
for Estates and Trusts, for 1995. The CCJT reported income and
expenses allocable to the jewelry business on Schedule C attached
to its return and also claimed deductions for fiduciary fees,
charitable contributions, and a distribution of the trust’s net
income to the CFT. The CCJT reported no taxable income and paid
no taxes for 1995. In respondent’s notice of deficiency to the
CCJT, respondent disallowed all of the CCJT’s deductions.
The CFT also filed a timely Form 1041 for 1995. The CFT
reported income it received from the CCJT on Schedule E attached
to its return. The CFT also claimed deductions for taxes,
fiduciary fees, charitable contributions, and medical, utilities,
automobile, and telephone expenses. The CFT reported no taxable
income and paid no taxes for 1995. In respondent’s notice of
deficiency to the CFT, respondent disallowed all of the CFT’s
deductions.
Petitioner reported fiduciary fees he received from the
CCJT, and Mrs. Castro reported fiduciary fees she received from
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011