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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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