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Gloria M. Richardson - Docket No. 16795-03
Year Deficiency
1996 $164,442
1997 123,848
The principal issues for decision in these consolidated cases
are:
(1) Whether trusts implemented and used by petitioners
during 1996 and 1997 should be disregarded for tax purposes as
sham entities lacking in economic substance, with resultant (a)
inclusion by petitioners of income reported by the trusts; (b)
recomputation of business deductions allowable to petitioners;
and (c) liability for self-employment taxes and entitlement to
corresponding deductions.
(2) Whether petitioners’ reported capital loss for both tax
years should be adjusted.
(3) Whether there exist underpayments due to fraud for 1996
and 1997 such that petitioner Homer L. Richardson
(Mr. Richardson) is liable for civil fraud penalties pursuant to
section 6663.
(4) Whether Mr. Richardson is liable for an accuracy-related
penalty pursuant to section 6662(a) with respect to that portion
of the deficiency for 1996 that is not attributable to fraud.
(5) Whether the statute of limitations bars assessment of
liabilities for 1996 and 1997.
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