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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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