Steve M. and Khristine Norton, et al. - Page 12




                                       - 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