Frank Aragona Trust, Paul Aragona, Executive Trustee v. Commissioner

Morrison, Judge:

The respondent (referred to here as the “IRS”) issued a notice of deficiency to the Frank Aragona Trust (sometimes referred to here as the “trust”), determining the following deficiencies in federal income tax and the following penalties:

Year Deficiency Accuracy-related penalty sec. 6662(a)

2003 $86,289 $17,257.80

2004 421,292 84,258.40

2005 -0--0-

2006 84,540 16,908.00

The trust filed a petition as permitted by section 6213(a). 1 We have jurisdiction to redetermine the deficiencies and penalties under section 6214(a). After concessions, 2 the two issues remaining for decision…