T.C. Memo. 2006-69 UNITED STATES TAX COURT HOMER L. RICHARDSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent GLORIA M. RICHARDSON, Petitioner v. COMMISSIONER OR INTERNAL REVENUE, Respondent Docket Nos. 16794-03, 16795-03. Filed April 11, 2006. Ps established a tiered trust arrangement and transferred to the entities their assets, including their personal residence and lifetime services. Held: The trusts implemented and used by Ps during 1996 and 1997 should be disregarded for tax purposes as sham entities lacking in economic substance, with resultant inclusion by Ps of income reported by the trusts, recomputation of business deductions allowable to Ps, and liability for self- employment taxes. Held, further, Ps are not entitled to capital loss amounts claimed for both years and must recognize a capital gain in 1997.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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