- 3 - (2) whether, in the alternative, petitioners carried their burden of proving that the income from petitioners’ respective trusts is not attributable to petitioners under the grantor trust rules; and (3) whether petitioners are liable for the section 6662(a) accuracy-related penalties determined by respondent. FINDINGS OF FACT Some of the facts have been stipulated and are so found. We incorporate the stipulated facts into our findings by this reference. Background Zalman Melnik and Lea Melnik (Lea) were married and resided in Houston, Texas, when they filed their petition. Moshe Melnik also resided in Houston, Texas, when he filed his petition. Hereinafter, we refer to these consolidated cases as this case. Zalman and Moshe Melnik3 (the Melniks) are brothers who grew up in Israel. In 1974, Moshe Melnik moved to Canada, where he attended college and received a degree in mechanical engineering. Moshe Melnik then worked in Canada as an engineer for a scrap metal company before moving to the United States in 1978 or 1979. In 1979, Moshe Melnik and his wife at the time, Barbara Melnik, formed HouTex, a scrap metal dealer involved in the 3Petitioner Moshe Melnik is sometimes referred to as “Mike Melnik”, and petitioner Zalman Melnik is sometimes referred to as “Sol Melnik” in the record in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011