Close v. Comr., T.C. Memo. 2014-25

(IRS claimed that petitioners' trusts for benefit of their children were shams; IRS failed to carry burden of proof; IRS bore burden of proof due to sham trust theory not being consistent with statutory notice of deficiency provided to petitioners; IRS failed to establish some of the factors required by Markosian v. Comr., 73 T.C. 1235 (1980)).