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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 that
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Last modified: May 25, 2011