Clark D. and Janis L. Pulliam - Page 3

                                        - 3 -                                         
          in Chapel to constitute control within the meaning of section               
          368(c), as required by section 355(a)(1)(D).                                
               The notice of deficiency sent to petitioners determined                
          that, in the event it is decided that Mr. Pulliam did not receive           
          dividends of $789,500 from Homes, Mr. Pulliam received $40,000 in           
          1992 as a downpayment on an installment sale of 49 percent of his           
          stock in Chapel, which petitioners did not report on their                  
          Federal income tax return for that year.3  This alternative                 
          determination was not placed in issue by petitioners.  Likewise,            
          petitioners did not allege errors in their petition with respect            
          to the disallowance of a personal exemption deduction, an                   
          adjustment to itemized/standard deductions, and the assertion of            
          an accuracy-related penalty under section 6662(a).                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and supplemental stipulation, together             
          with attached exhibits, are incorporated herein by this                     
          reference.                                                                  
               Clark D. Pulliam and Janis L. Pulliam (petitioners) resided            
          in Robinson, Illinois, at the time they filed their petition in             
          this case.                                                                  



               3    According to Mr. Pulliam's testimony, the $40,000 was             
          omitted from petitioners' Federal income tax return, but it was             
          later reported and an advance payment was made on the deficiency            
          determined for 1992.                                                        




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