WESENBERG v. COMMISSIONER

Docket No. 561-76.

69 T.C. 1005 (1978)

RICHARD L. WESENBERG AND NANCY E. WESENBERG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 29, 1978.


Attorney(s) appearing for the Case

Pipp M. Boyls, for the petitioners.

Fredrick B. Strothman, for the respondent.


FAY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1972 of $4,222, plus an addition to tax under section 6653(a)1 of $211.

The issues for decision are: (1) Whether the purported conveyance by petitioner Richard L. Wesenberg of his lifetime services to a family trust was effective to shift the incidence of taxation on amounts representing compensation to him but paid to the trust; (2) whether...

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