- 2 -
Respondent's amended answer asserted the delinquency and
negligence additions to tax under sections 6651 and 6653(a),
respectively, in the alternative to the fraud addition to tax.
Unless otherwise noted, all section references are to the
Internal Revenue Code 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 are:
(1) Whether payments received by petitioner constituted loan
repayments or constructive dividends; (2) whether payments made
to petitioner's son constituted constructive dividends to
petitioner; (3) whether petitioner is liable for the fraud
addition to tax, or, in the alternative, for the delinquency and
negligence additions to tax; and (4) whether petitioner is liable
for the addition to tax for failure to pay estimated taxes.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided in Mobile,
Alabama.
Petitioner graduated from high school and attended 2 years
of college. Petitioner worked in the finance industry before
entering the retail furniture business in 1960.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011