Ronald D. Weeldreyer and Suzanne Weeldreyer - Page 31

                                                - 31 -                                                  
                                                            11/30/95   11/30/96   11/30/97              
             Weeldreyer notice of deficiency adjustment                                                 
             for food & lodging provided by Dreyer Farms $12,433       $19,919    $19,573               
             Food & lodging expenditures                    9,908      12,448      12,975               
             Adjustment for rental value of residence       2,525      7,471      6,598                 
                  The Weeldreyers have not shown that the portion of the rent                           
            attributable to the farmhouse is less than the amounts for the                              
            years at issue, as computed above.  We therefore hold that those                            
            amounts are properly included in the Weeldreyers’ income for the                            
            years at issue.                                                                             
                  5.    Summary of Adjustments to Weeldreyers’ Income                                   
                  The Weeldreyers’ income from farming is increased by $2,525                           
            in 1995, $7,471 in 1996, and $6,598 in 1997 to reflect the                                  
            disallowance of deductions for the rental value of the farmhouse.                           
            In addition, the following personal expenses paid by Dreyer Farms                           
            are included in the Weeldreyers’ income as constructive dividends                           
            for the years at issue:                                                                     
                                                  1995              1996         1997                   
             Food                                 $4,406        $7,179        $7,712                    
             Utilities                            1,694         2,362         2,235                     
             Landscaping                          256           216     --                              
             Remodeling costs                     1,729         --            --                        
             Repairs and maintenance              --            82     --                               
             Telephone                             –-              –-          338                      
             Total                                8,085         9,839         10,285                    
            Issue 2. Accuracy-Related Penalty Under Section 6662(a)                                     
                  Respondent determined that Dreyer Farms is liable for the                             
            accuracy-related penalty under section 6662(a).  As pertinent                               
            here, section 6662(a) imposes a 20-percent penalty on the portion                           




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