Estate of H.A. True, Jr. - Page 267




                                       - 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).                                                                      




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