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Respondent determined that for 1983, 1984, 1985, and 1986,
Elvin received total constructive dividends from YOC of $235,664,
$326,156, $291,331, and $274,075 (the taxable portion of which
for 1986 is limited to $196,042 as a result of YOC's 1986
earnings and profits), respectively.
Also, as explained, respondent determined that for 1983 and
1985 Elvin received income in the form of travel awards received
from General Motors of $4,361 and $10,087, respectively.
The schedule below reflects for 1983, 1984, 1985, and 1986
Elvin's taxable income as reported by Elvin on his Federal income
tax returns, Elvin's taxable income as determined by respondent,
and Elvin's underreported taxable income as determined by
respondent (namely, Elvin's taxable income as determined by
respondent less Elvin's reported taxable income).
Taxable Income
Underreported
Income
As Reported As Determined as Determined
Year by Elvin by Respondent by Respondent
1983 $103,285 $434,279 $330,994
1984 283,714 612,362 328,648
1985 219,427 520,845 301,418
1986 209,743 399,785 190,042
Respondent also determined that for 1983, 1984, 1985, and
1986, Elvin was liable for the fraud additions to tax, increased
interest relating to fraud, and substantial understatement
additions to tax.
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