- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined deficiencies in and additions to tax with respect to petitioners’ Federal income tax for 1999 as follows: Additions to tax/penalties Internal Revenue Code Docket No. Deficiencies Sec. 6651(a)(1) Sec. 6662(a) 2275-04 $112,919 $16,937.85 $22,583.80 2276-04 347,030 52,054.50 69,406.00 2277-04 374,189 56,128.35 74,837.80 2278-04 373,621 56,043.15 74,724.20 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The deficiencies included “whipsaw” determinations against petitioner trusts in the event that the validity of the trusts was sustained by the Court. However, in a stipulation of settled issues, the parties agreed: 1. Stejskal Enterprises Trust, Bioactive Kansas Trust, and Total Health Center Trust should be disregarded for tax purposes because the trusts were grantor trusts, lacked economic substance, or were assigned income attributable to Petitioners Kenneth W. Stejskal, Sr. and Jane Stejskal. * * * * * * * 3. All income reported by Stejskal Enterprises Trust, Bioactive Kansas Trust, and Total Health Center Trust is properly reportable by Petitioners Kenneth W. Stejskal, Sr. and Jane Stejskal on their Individual Income Tax Return, Form 1040, on Schedule C, Profit or Loss from Business.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011