- 12 - determined that the Denali Company Trust did not substantiate the amounts. Additionally, respondent imposed an addition to tax under section 6651(a)(1) for failure to file in 1995 and accuracy-related penalties under section 6662(a) for 1995 and 1996. On their 1995 and 1996 tax returns received on September 23, 1996, and June 13, 1997, respectively, Mr. and Mrs. Norton did not report any of the income reported by the Denali Company Trust. In the notice of deficiency for 1995 and 1996, 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. Respondent also imposed an addition to tax under section 6651(a)(1) for failure to file in 1995, and accuracy- related penalties under section 6662(a) for 1995 and 1996.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011