James D. and Rita K. Snyder - Page 1

                                 T.C. Memo. 2001-255                                  

                               UNITED STATES TAX COURT                                

                     JAMES D. AND RITA K. SNYDER, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11638-99.               Filed September 28, 2001.           

                    R attributed to Ps’ various items with respect to                 
               two trusts, on the grounds that such trusts were either                
               shams or grantor trusts, on the ground that the                        
               assignment of income doctrine applied, or on the ground                
               that Ps failed to report certain trust items.  R                       
               determined a sec. 6662(a), I.R.C., accuracy-related                    
               penalty against Ps.  At trial, R moved for penalties                   
               on account of delay and for other reasons, under                       
               sec. 6673(a)(1), I.R.C.                                                
                    1.  Held:  Trust income attributed to Ps for                      
               substantially the reasons stated by R.                                 
                    2.  Held, further, Ps are liable for accuracy-                    
               related penalties under sec. 6662(a), I.R.C.                           
               3.  Held, further, for various reasons, Ps are                         
               liable for a penalty under sec. 6673(a)(1), I.R.C.                     

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