- 2 -
MTS International, Inc.
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6653(a)(1)(A)1 Sec. 6661
1987 $217,716 $54,429 $10,885 $54,429
1 Respondent determined an addition to tax under sec.
6653(a)(1)(B) of 50 percent of the interest due on $217,716 for
1987.
Robert C. Hughes III
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1)(A)1 Sec. 6661
1986 $31,740 $13,179 $3,236 $7,935
1987 202,446 49,951 11,190 50,612
1 Respondent determined additions to tax under sec.
6653(a)(1)(B) of 50 percent of the interest due on $31,740 for
1986, and 50 percent of the interest due on $202,446 for 1987.
After concessions, the issues for decision are:
1. Whether the loss petitioner Robert C. Hughes III
sustained when he sold ZZZZ Best Co. stock in 1987 is deductible
as a theft loss. We hold that it is not.
2. Whether petitioner Robert C. Hughes III’s withdrawals
from petitioner MTS International, Inc. (MTS), and what
petitioners contend was its forgiveness of his debts were
constructive dividend income to him in the amount of $194,224 in
1987. We hold that they were, except as discussed below.
Page: 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