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Additions to Tax & Penalties
Sec. Sec. Sec. Sec.
Docket No. Year Deficiency 6653(a)(1) 6653(a)(2) 6661 6662(a)
19395-93 1989 $173,021 -- -- -- $ 34,604
(George & 1990 667,786 -- -- -- 133,557
Judith
Georgiou)
19396-93 1989 88,493 $4,425 To be $22,123 --
(Kolonaki determined
Imports, 1990 555,515 -- -- -- 111,103
Inc.)
19397-93 1989 44,261 2,214 To be 11,065 --
(Georgiou determined
Retail
Stores)
(References to the tax year for the corporations are to the
applicable fiscal year.)
Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended and in effect for the years
in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions, the issues remaining for decision as to
Kolonaki Imports, Inc. (Kolonaki), are: Whether Kolonaki was
qualified to file a consolidated return with Judy Alexander, Inc.
(JAI), a corporation wholly owned by George Georgiou (Georgiou),
for the year ended September 30, 1990; whether Kolonaki is liable
for a penalty under section 6662(a) for 1990; and whether
Kolonaki is liable for additions to tax under sections 6653(a)(1)
and 6661 for 1989. The issues remaining for decision as to
Georgiou are: Whether amounts transferred to Georgiou from
Kolonaki in 1989 and 1990 constituted loans or constructive
dividends; whether a $100,000 home interest deduction claimed by
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Last modified: May 25, 2011