-2- amounts as charitable contributions. We hold they may not. We also decide whether petitioners are liable for the accuracy-related penalty determined by respondent under section 6662(a). We hold they are. Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts were stipulated. The stipulated facts and the exhibits submitted therewith are incorporated herein by this reference. We find the stipulated facts accordingly. Petitioners, husband and wife, resided in San Jose, California, when their petition was filed. They filed a joint 1999 Form 1040, U.S. Individual Income Tax Return. That return reported that petitioners’ 1999 total income was $19,504 and that their total tax for that year was $1,024. That return reported that their total income was attributable to (1) $19,365 of compensation received by petitioner Jerry L. Hill (Hill) from Re-Cap Trust and (2) $139 of tax-exempt interest. Hill is a college-educated individual who has worked in California for more than 2 decades as a real estate broker. In or about 1995, he attended some seminars promoting the use of trusts to shelter his liability for Federal income taxes. He shortly thereafter formed Re-Cap Trust and transferred most ifPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011