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CHRISTAL v. COMMISSIONER

Docket No. 12793-96.

76 T.C.M. 97 (1998)

T.C. Memo. 1998-255

Neil J. Christal, II and Kathryn E. Christal v. Commissioner.

United States Tax Court.

Filed July 13, 1998.

Attorney(s) appearing for the Case

Dana C. Christian and David Prince, for the petitioners. Laurel Robinson and Thomas G. Schleier, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $36,856, an addition to tax under section 6651(a)(1) of $9,193, and a penalty under section 6662(a) of $7,371 in petitioners' 1992 Federal income tax.1

The issue for decision is whether United Sovereigns "A Trust" (United Sovereigns) is a nullity or sham trust.2

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