MatrixInfoSys Trust - Page 2




                                        - 2 -                                         
                                       Additions to Tax           Penalty            
          Petitioner     Year   Deficiency   Sec. 6651(a)(1)  Sec. 6654   Sec. 6662(a)
          MatrixInfoSys   1995$23,789           –-            --          $4,758      
          Trust     1996      23,666         --        --           4,733             
          Andy Hromiko    1994    $20,340         $5,085        $1,055          --    
          1995     20,176          5,044         1,094          –-                    
          1996     19,447          4,862         1,035          –-                    
          1997     18,366          4,592           983          –-                    
               Unless otherwise stated, all section references are to the             
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               We must resolve a basic dispute between the parties:                   
          whether certain payments made to a trust, MatrixInfoSys (the                
          trust), on account of services performed by Andy Hromiko                    
          (petitioner) should have been returned as income on petitioner’s            
          individual tax return.  Because respondent adopted “whipsaw”                
          positions in making the determinations against petitioner and the           
          trust, respondent will concede the tax liabilities determined               
          against the trust if the Court concludes that the payments made             
          to the trust are properly taxable to petitioner.                            
                                  FINDINGS OF FACT                                    
               At the time of the filing of the trust’s petition, the                 
          trust’s address was in Roseville, California.  Similarly, at the            
          time petitioner filed his petition, he resided in Roseville,                
          California.  Before setting out our specific factual                        









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Last modified: May 25, 2011