Virginia A. Fox, et al. - Page 5




                                        - 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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