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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.
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Last modified: May 25, 2011