2 submitted to the Court on a full stipulation of facts and exhibits without trial, pursuant to Rule 122. All statutory references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted. On September 2, 1994, respondent determined deficiencies in petitioners' 1991 Federal income taxes in the following amounts: Petitioners Docket No. Deficiency Michael & Teresa Hillyer 22118-94 $13,798 David D. & Linda J. Hillyer 22119-94 13,576 William H., Jr., & Kim Rae Hillyer 22120-94 12,724 William H., Sr., & Elizabeth Hillyer 22121-94 44,077 All the above petitioners, husbands and wives, filed joint income tax returns for the year 1991 at Kansas City, Missouri, and, at the time of filing the petitions herein, all such petitioners were residents of Illinois. All the male petitioners (petitioners) herein were stockholders of Hillyer Excavating Service, Inc. (the corporation), whose name was changed to Hillyer, Inc., in 1992. During the 1991 calendar year, the shares of the corporation were owned as follows: Percent Michael Hillyer 15.44 David D. Hillyer 15.47 William Hillyer, Jr. 15.47 William Hillyer, Sr. 53.59 Total 100 For the year 1991, the corporation filed Form 1120-S as an S corporation, and attributed its net income to petitioners inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011