Steve M. and Khristine Norton, et al. - Page 8




                                        - 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. to                   





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