Harlan D. Edwards and Floors by Harlan, Jody Edwards, Trustee - Page 3

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               (3) whether Floors Trust is entitled to deductions taken for           
          rent, income tax expense, and income distributions;                         
               (4) whether Harlan is liable for self-employment tax;                  
               (5) whether Harlan is liable for an addition to tax pursuant           
          to section 6651(a)(1); and                                                  
               (6) whether Harlan is liable for an addition to tax pursuant           
          to section 6654.                                                            
                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which are               
          incorporated herein by reference.  Harlan resided and Floors                
          Trust had an address in San Jose, California, at the time the               
          petition was filed.                                                         
               Before 1995, Harlan operated a vinyl floor installation                
          business, known as Edwards Vinyl Floors (Edwards Vinyl), as a               
          sole proprietorship.  Harlan managed the business, owned its                
          assets, and performed the installation work along with his son,             
          Jody Edwards (Jody).                                                        
               In January 1995, Harlan was the grantor of three trusts:2              
          Floors Trust, Harwood Group Trust (Harwood Group), and Harwood              
          Holding Co. Trust (Harwood Holding).                                        
          Harlan got the idea of putting his business and assets into                 
          trusts through the advice of Don Fletcher, a trust promoter who             


               2 By use of the terms “trust”, “trustee”, “beneficiary”, and           
          other related terms, we intend no implication as to the validity            
          of the trusts involved in this case.                                        




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