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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a $5,415 deficiency in petitioners’
Federal income tax for 2003 and a $1,083 penalty under section
6662(a). After a concession by respondent,1 the issue for
decision is whether petitioners must include in gross income a
$45,033 distribution from a trust.
Background
The parties stipulated some of the facts, and they are so
found. We incorporate the stipulation of facts and attached
exhibits herein by this reference. At the date of filing the
petition, petitioners resided in El Sobrante, California.
Patrick Purcell (Mr. Purcell), petitioner Carolee Purcell’s
father, and Sherry Purcell,2 her sister, lived in Michigan in
2003. Patrick Purcell died in August 2003. Mr. Purcell named
petitioner Carolee Purcell and Sherry Purcell (sometimes
hereinafter referred to as the sisters) copersonal
representatives of his estate and cotrustees of his trust, the
1 At trial, respondent conceded the accuracy-related penalty
under sec. 6662(a).
2 Sherry Purcell is also referred to as Sherry Knorr in the
record. The Court will refer to her as Sherry Purcell or as
petitioner Carolee Purcell’s sister.
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Last modified: March 27, 2008