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Petitioners and the petitioner trusts filed their Federal
income tax returns for 1995, 1996, and 1997 on April 15, 1996 and
1997 and August 15, 1998, respectively.
Except for the 1997 return filed by The Connell Vehicle Co.
#101, which identified The Connell Family Trust as the
beneficiary, the returns filed by The Connell Vehicle Co. and The
Connell Vehicle Co. #101 identified The Connell Business Co. as
the trusts’ beneficiary.
The returns filed by The Connell Business Co. identified The
Connell Family Trust as the beneficiary.
The 1995 and 1996 returns filed by The Connell Family Trust
identified petitioners and The Connell Charitable Trust as
beneficiaries. The Connell Family Trust return for 1996 reported
distributions of $6,068 to each of the petitioners.
Petitioners’ individual returns made no reference to the
petitioner trusts or in any way indicated that petitioners were
associated with, beneficiaries of, or recipients of income from,
the petitioner trusts. With regard to the $6,068 of income
reported as allocated to each of petitioners in the 1996 return
for The Connell Family Trust, petitioners’ 1996 return listed
that income in Schedules C, Profit or Loss From Business, (one
for each petitioner) as “Gross receipts or sales”. The Schedules
C contain no information that would suggest that The Connell
Family Trust was the source of that income. Petitioners reported
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Last modified: May 25, 2011