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and 1997 that respondent determined in the notice issued to
Herbst Charitable Trust4 in the case at docket No. 10000-00;5
(3) the accuracy-related penalty under section 6662(a) that
respondent determined for each of the taxable years 1996 and 1997
in the notice issued to Andrea Herbst (Ms. Herbst) in the case at
docket No. 10001-00; and (4) the accuracy-related penalty under
section 6662(a) for each of the taxable years 1996 and 1997 that
respondent determined in the notice issued to Ronald Herbst (Mr.
Herbst) in the case at docket No. 10002-00.
Background
The record establishes and/or the parties do not dispute the
following:
At the time the respective petitions in these cases were
filed, Herbst Management Trust, Herbst Charitable Trust, Ms.
Herbst, and Mr. Herbst listed in those petitions the same address
in Canton, Ohio.
4When referring in this Opinion to Herbst Charitable Trust,
our use of the word “Trust” and any similar words are for conve-
nience only and is not intended to convey any meaning or have any
significance for Federal tax purposes.
5In the notice issued to Herbst Charitable Trust, respondent
also determined to impose the accuracy-related penalty under sec.
6662(a) for each of the taxable years 1996 and 1997. At the
trial, respondent indicated that respondent was abandoning
pursuing the determinations in the notice issued to Herbst
Charitable Trust to impose the penalty under sec. 6662(a) for
each of the taxable years 1996 and 1997.
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