John E. Rogers & Frances L. Rogers v. Commissioner

T.C. Memo. 2014-141

UNITED STATES TAX COURT JOHN E. ROGERS AND FRANCES L. ROGERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7390-10. Filed July 17, 2014. In 2004 Ps owned and operated several tiered business entities that promoted tax sheltered investments involving the purchase and sale of Brazilian receivables, brokered and developed real property, and attempted to bring a medical device to market. Ps failed to report as income some of the gross receipts of their business entities, and Ps contend that the unreported amounts were held “in trust” for another…