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were, in substance, the grantors of the trust. Thus, the income
and expenses from the operations of the pest control business
during the years in issue are attributable to the Morrows and not
to the trust. The Morrows are liable for self-employment taxes
on the net income of I.D.F. Pest Control Co. for the years in
issue.
To reflect the foregoing and concessions of the parties,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011