CIM Trust - Page 2




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          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 they                








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