- 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
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