- 2 - CIM Trust, Charlotte Morrow, Trustee Docket No. 18689-99 Penalty Year Deficiency Sec. 6662(a) 1996 $5,713 $1,143 1997 28,128 5,626 Peter and Charlotte I. Morrow Docket No. 18690-99 Penalty Year Deficiency Sec. 6662(a) 1996 $3,118 $624 1997 6,379 1,276 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by the parties, the issue remaining for decision is whether petitioner CIM Trust (the trust) should be disregarded for Federal income tax purposes and the income and expense from the business operations of I.D.F. Pest Control Co. attributed to petitioners Peter Morrow and Charlotte I. Morrow (the Morrows). FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Peter Morrow and Charlotte I. Morrow (Charlotte Morrow), husband and wife, resided in Humble, Texas, at the time theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011