Walter J. & Virginia L. Ward, et al. - Page 4




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          Business, realty advertising and auto expenses for 1996 and 1997            
          were reduced to zero because they did not establish the expenses            
          were paid during the taxable years and that they were ordinary              
          and necessary to their business; (4) the Wards’ Schedule C video            
          cost of goods sold and supplies expenses for 1996 and 1997 were             
          reduced to zero because they did not establish they were paid               
          during the taxable years and that they were ordinary and                    
          necessary to their business; (5) the Wards’ Schedule C video                
          depreciation expenses for 1996 and 1997 were reduced to zero                
          because they did not establish the basis of the assets, that the            
          assets were depreciable, and that they were ordinary and                    
          necessary to their business; (6) the Wards’ Schedule E,                     
          Supplemental Income or Loss, income was increased by $407,362 for           
          1996 and $448,253 for 1997 because (a) the Wards’ trust                     
          arrangements were shams or grantor trusts, or alternatively due             
          to assignment of income, (b) of income from a partnership, and              
          (c) of failure to establish that $1,487 for 1996 from Video City            
          Shepard and $4,576 for 1997 from Arctic Video City were losses              
          the Wards sustained; (7) self-employment tax adjustments for 1996           
          and 1997; and (8) accuracy-related penalties for 1996 and 1997              
          due to negligence or substantial understatement of tax.                     
               In the notices of deficiency issued to ASI, GND, WT, and GNI           
          (collectively, the trusts) respondent took protective,                      








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