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SMITH v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 14900-15.

151 T.C. 41 (2018)

BARRY M. SMITH AND ROCHELLE SMITH, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 18, 2018.

Attorney(s) appearing for the Case

Desiree E. Fernandez , Jose M. Ferrer , Summer A. Lepree , Jeffrey L. Rubinger , and Samuel C. Ullman , for petitioners.

Jeffrey B. Fienberg , Michael S. Kramarz , Sergio Garcia-Pages , and Richard A. Rappazzo , for respondent.

OPINION

During 2008 and 2009 petitioners owned, through a pair of domestic grantor trusts and an S corporation, controlled foreign corporations (CFCs) incorporated in Hong Kong and later in Cyprus. The Internal Revenue Service (IRS or respondent) determined that petitioners during these years had received actual or constructive...

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