- 333 -
explicitly stated that for every business deal they would
consider its tax consequences, and they would evaluate whether to
litigate potentially controversial tax issues. In the cases at
hand, the True family was well aware of the issues in controversy
and the dollars at stake. They took aggressive positions on the
estate and gift tax returns to test the effectiveness of the buy-
sell agreements to fix transfer tax values. They did not rely,
in good faith, on professional appraisals or obtain professional
advice on the effects of the decisions in the prior gift tax
cases. Accordingly, we hold that the reasonable cause exception
to the accuracy-related penalties does not apply to the cases at
hand.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
100(...continued)
P.2d 991 (Wyo. 1978); True Oil Co. v. Gibson, 392 P.2d 795 (Wyo.
1964).
Page: Previous 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 NextLast modified: May 25, 2011