Steve M. and Khristine Norton, et al. - Page 11




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               On their 1994 return received on January 3, 1996, Mr. and              
          Mrs. Norton did not report any income from the Denali Company               
          Trust.  In the notice of deficiency, in addition to the                     
          imposition of an addition to tax under section 6651(a) and an               
          accuracy-related penalty under section 6662(a), respondent                  
          increased their self-employment income by the net business income           
          of Denali Company Trust.  Respondent determined that,                       
          alternatively:  (1) The Denali Company trust is a sham with no              
          economic substance; (2) the Denali Company Trust is a grantor               
          trust; and (3) Mr. and Mrs. Norton’s attempted assignment of                
          income to the Denali Company Trust is not recognized for tax                
          purposes.                                                                   
               On its 1995 return received on September 23, 1996, Denali              
          Company Trust reported an adjusted gross income of $116,752.  It            
          deducted the same amount, of which $116,452 was treated as an               
          income distribution.  As a result, it did not report any taxable            
          income in 1995.                                                             
               On its 1996 return, Denali Company Trust reported an                   
          adjusted gross income of $171,329.  It deducted the same amount,            
          of which $171,029 was treated as an income distribution.  As a              
          result, it did not report any taxable income in 1996.                       
               In the notice of deficiency for 1995 and 1996, respondent              
          disallowed business expense deductions for depreciation, legal              
          and professional fees, and seminars, because respondent                     






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