- 6 - in taxable income for 1997. These returns reported Federal income tax liabilities of $2,465 for 1996 and $4,497 for 1997. Each of the trusts filed Forms 1041, U.S. Income Tax Return for Estates and Trusts, for tax years 1996 and 1997 reporting negative taxable income.2 Petitioner did not keep a general ledger accounting system. Instead, petitioner’s counsel admitted at trial that petitioner’s records consisted of “just gross receipts, a massive amount of receipts, he does not keep journals and stuff like that”. On June 13, 1996, respondent sent a form letter to petitioner’s current spouse, Jeanee Girazian, who at the time was living with and working for petitioner and was a named trustee of his trusts. Respondent’s letter stated that he had information that Ms. Girazian might be involved in trust arrangements used for tax avoidance purposes. The letter cited substantial authority holding abusive trusts invalid and recommended that Ms. Girazian obtain independent advice regarding the validity of the trusts. 2Respondent issued notices of deficiency to the trusts disallowing all trust deductions. The trusts failed to file petitions to the Tax Court within the 90-day period provided by sec. 6213(a). Respondent thereupon assessed deficiencies against the trusts. Respondent has agreed to hold in abeyance efforts to collect the assessed deficiencies from the trusts while the case at hand is pending. In view of the agreement of the parties in the case at hand that the trusts should be disregarded for Federal income tax purposes since their inception, it is understood that the assessments against the trusts will be abated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011