Shirley L. Johnson - Page 2




                                        - 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 against                       






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011