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 in
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011