- 8 - Respondent asserted that, alternatively: (1) The trust arrangements are a sham and are disregarded for tax purposes; (2) the South Denali Lands Trust is a grantor trust whose income is taxable to Mr. and Mrs. Norton; and (3) the assignment of income to the South Denali Lands Trust is not recognized for tax purposes and is taxable to Mr. and Mrs. Norton. Additionally, respondent imposed an addition to tax under section 6651(a)(1) for failure to file and an accuracy-related penalty under section 6662(a). Denali Company Trust The Denali Company Trust was created in 1993 and is doing business as SNE. The Denali Company Trust owns trucks, equipment, and tools. These items were owned and used in the construction business by Mr. and Mrs. Norton and then transferred to the Denali Company Trust. Mr. Owens and Mr. Crockett are the trustees and the signatories on the bank account. David Norton is the protector of the trust. The beneficiaries are the Crystal Diversified Trust and Michael Andr�. Mr. Norton is the general manager. Mr. Norton’s day-to-day conduct of business has not changed due to the formation of the Denali Company Trust, except that the trust required Mr. Owens’ permission on large projects. The trustees approved a resolution that would allow Mr. Norton the following duties as manager: * * * lend his name, reputation, goodwill, and good credit standing, licenses and authorizations etc. toPage: 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