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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