- 2 - to avoid income tax with respect to its shareholders. 2. Held, further, most of the legal expenses in issue are not deductible under sec. 162, I.R.C. 3. Held, further, M had constructive dividend income. 4. Held, further, NITCO is liable for the additions to tax. 5. Held, further, M and M’s wife are liable for the additions to tax. David J. Duez, Gail H. Morse, and Roger W. Wenthe, for petitioners. Marjory A. Gilbert, Linda Grobe, and Claire McKenzie, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows: Northwestern Indiana Telephone Co. docket No. 7970-91 Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 6662 1987 $786,115.00 $39,305.75 1 $182,675.75 -- 1988 429,006.00 21,450.30 -- 101,935.50 -- 1989 329,369.00 -- -- -- $23,509.40 150 percent of the interest due on $55,412.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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