Northwestern Indiana Telephone Company - Page 2

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                  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.                                                     








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