Virginia A. Fox, et al. - Page 2




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          notice of deficiency issued to petitioners that they were liable            
          for a $66,798 deficiency, a $16,149 late-filing addition to tax             
          under section 6651, and a $13,360 accuracy-related penalty for              
          negligence under section 6662.2  For 1995, respondent determined            
          in a notice of deficiency issued to Roland Fox (Mr. Fox) that he            
          was liable for a $107,919 deficiency, a $26,408 late-filing                 
          addition to tax under section 6651, and a $5,751 addition to tax            
          under section 6654 for underpayment of estimated tax.  For 1995,            
          respondent determined in a notice of deficiency issued to                   
          Virginia Fox (Ms. Fox) that she was liable for a $90,261                    
          deficiency, a $21,994 addition to tax under section 6651, and a             
          $4,788 addition to tax under section 6654 for underpayment of               
          estimated tax.                                                              
               Following our consolidation of the three cases for purposes            
          of trial, briefing, and opinion, we must decide whether                     
          respondent’s determinations are correct.  Our decision rests                
          primarily on whether we should disregard petitioners’ trust,                
          Prindle International Marketing Trust (Prindle Trust), for                  
          Federal income tax purposes.  We hold that we shall disregard the           
          Prindle Trust and that respondent’s determinations are correct to           
          the extent stated herein.                                                   




               2 Section references are to the Internal Revenue Code in               
          effect for the years in issue.  Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      




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