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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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