Michael Scott Ioane and Shelly Jean Olson-Ioane created five trusts of their own and were involved in another taxpayer’s corporation. These six entities were the heart of this court case. The apparent purpose of the entities was to reduce the Ioanes’ taxable income. This did not work out well, as the court agreed with the IRS and imposed1

taxes of $2.4 million,

late filing penalties of $315,754,

accuracy-related penalties of $512,000, and

$10,000 in frivolous and groundless argument penalties.

Trusts as Disregarded Entities

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