- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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