William C. Sampson and Lucille A. Sampson v. Commissioner of Internal Revenue

The Lucille A. Sampson Pure Equity Trust (Trust) appeals the Tax Court’s denial of a petition to intervene in tax deficiency litigation between the Commissioner of Internal Revenue and William and Lucille Sampson. For the reasons stated below, we vacate the Tax Court’s decision and remand for further proceedings.

The Commissioner sent a notice of deficiency to William and Lucille Sampson in their individual capacities. The Sampsons, who also are trustees of the Trust, allegedly had attempted to avoid paying income tax by attributing portions of their income to the Trust. Two other trustees,…