- 11 - 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 respondentPage: 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