- 2 - Elvin P. Yarbrough Additions to Tax Sec. Sec. Sec. Sec. 6653 6653 6653 6653 Sec. Year Deficiency (b)(1) (b)(2) (b)(1)(A) (b)(1)(B) 6661 1983 $165,498 $104,567 * $41,374 1984 164,324 148,555 * 41,081 1985 150,708 75,354 * 30,177 1986 95,021 $71,266 * 23,755 * 50 percent of interest due on portion of underpayment attributable to fraud. Yarbrough Oldsmobile Cadillac, Inc. Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(2) 6661 1983 $33,649 $16,825 * $8,412 1984 18,097 9,048 * 4,524 1985 34,118 17,059 * 8,529 * 50 percent of interest due on portion of underpayment attributable to fraud. Unless otherwise indicated, 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 settlement of some issues, the issues for decision in these consolidated cases are: (1) Whether petitioner Yarbrough Oldsmobile Cadillac, Inc. (YOC), is entitled to certain claimed business expense deductions disallowed by respondent; (2) whether petitioner Elvin P. Yarbrough (Elvin) is to be treated as having received constructive dividends from YOC, and, if so, the amount of the constructive dividends; (3) whether prizes and awards thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011