Homer L. Richardson - Page 1

                                 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.                                                  







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