- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011