- 19 - Although the McKenzie Trust was ostensibly engaged in the business of restoring Model T Fords, it was petitioner who worked full time to order automotive parts from suppliers, to purchase rusted Model T Ford chassis, and to restore them into finished, operable, and safe Model T Ford speedsters for resale at auctions. Mr. Boatright signed checks from the trust’s bank account in advance so that petitioner could fill them out when he purchased automobile parts. The McKenzie Trust had no employees other than petitioner, and all of the income earned by the McKenzie Trust was attributable to petitioner’s labor. No agent of Glenmere Investments was ever involved with the automobile restoration business allegedly conducted by the McKenzie Trust. Petitioner filed Forms 1041 for the taxable years 1995 through 1998 in the name of the McKenzie Trust, which were signed by Mr. Boatright. The 1995 and 1996 returns claimed income distribution deductions for amounts allegedly distributed to Glenmere Investments, and the trust did not pay any income taxes in 1995 or 1996. On the McKenzie Trust’s 1996 return, petitioner’s management fees were deducted on Schedule C, Profit or Loss From Business, as legal and professional services in computing the trust’s income that was distributed. For the taxable year 1997, the management fees paid to petitioner exceeded the McKenzie Trust’s income, and, as a result, thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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