- 2 - OPINION COHEN, Judge: In the case at docket No. 6452-99, respondent determined deficiencies of $12,476 and $15,260 and accuracy- related penalties under section 6662(a) of $2,495.20 and $3,052, with respect to Federal income taxes of petitioner Shirley L. Johnson (Johnson) for 1996 and 1997, respectively. The deficiencies and penalties were attributable to adjustments related to Johnson’s receipt of income from NJSJ Asset Management Trust (NJSJ Trust). In the case at docket No. 6453-99, respondent determined deficiencies of $14,056 and $17,593 and accuracy-related penalties under section 6662(a) of $2,811 and $3,519 with respect to petitioner NJSJ Trust’s tax liability for 1996 and 1997, respectively. Those deficiencies were attributable to respondent’s disallowance of Schedule C, Profit or Loss From Business, expenses, charitable contributions, and an income distribution deduction claimed by NJSJ Trust. The primary issue in these consolidated cases is whether income reported by NJSJ Trust is taxable to Johnson on alternative grounds of lack of economic substance, assignment of income, or grantor trust principles. The cases are now before the Court, however, on respondent’s motions to dismiss each of the cases for lack of prosecution and for the Court to determine the penalty to be awarded to the United States againstPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011