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1. Introduction
Notwithstanding the lack of merit to petitioners’ arguments,
petitioners have assigned error to respondent’s adjustments. The
evidence supports those adjustments, and petitioners have offered
nothing in rebuttal. Based on the facts we have found, we infer
(and find) the following additional facts: Both before and after
the years in issue, petitioners carried on a proprietorship
variously called “Complete Connection”, “Complete Connections”,
or “Complete Connections Computer Systems” (without distinction,
Complete Connections). During such preceding and following
years, under the name Complete Connections, petitioners provided
tax preparation, bookkeeping, and accounting services, and
engaged in certain computer related services. During the years
in issue, petitioners engaged in some or all of those activities
and reported gross receipts from such activities and
miscellaneous related items of income on returns they made for
Complete Connections Trust. Petitioners exercised control over
Complete Connections Trust, as evidenced by their signatures, as
fiduciaries, on the Complete Connections Trust returns and their
authority to write checks on the Complete Connections checking
account. Petitioners distributed the income of Complete
Connections Trust to J&R Trust. J&R Trust reported such income
and also reported gross receipts from business and interest.
Petitioners transferred their residence to J&R Trust, but
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