- 5 -
1994 1995
Petitioners Mr. Fox Ms. Fox
Exemption -0- ($2,500) ($2,500)
Commission inc.–-Oxyfresh $191,510 225,658 225,658
Dividend income 1,580 -0- -0-
Interest income -0- 138 -0-
Half of community int. inc. -0- -0- 69
Taxable SSA 4,082 7,191 -0-
Half community taxable SSA -0- -0- 3,596
Pension/annuity -0- 26,638 -0-
Half community pension/annuity -0- -0- 13,319
Net rental inc. -0- 19,262 19,262
Self-employment tax deduction (6,322) (6,816) -0-
Standard deduction -0- (3,275) (3,275)
Deduction for exemptions 1,372 2,500 2,500
Total 192,222 268,796 258,629
OPINION
The parties dispute whether the Prindle Trust is a sham.
Respondent argues it is. Petitioners argue it is not. We agree
with respondent.
Petitioners concede that the Prindle Trust is the same trust
that was at issue in Prindle Intl. Mktg., UBO v. Commissioner,
supra, but assert baldly that the Prindle Intl. Mktg., UBO case
was wrongly decided by both this Court and the Court of Appeals
for the Ninth Circuit. In that case, we held in relevant part
that: (1) The Prindle Trust was a sham not to be recognized for
Federal income tax purposes for 1992 or 1993, (2) petitioners
were liable for self-employment tax on the payments which they
received from Oxyfresh during 1992 and 1993, (3) petitioners were
liable for a failure-to-file addition to their 1993 tax under
section 6651, and (4) petitioners were liable for the
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