- 33 -
for a substantial understatement of tax liability under section
6661(a) and for increased interest on tax-motivated transactions
under section 6621(b) for 1988. These additions to tax, too,
were applied with respect to petitioners’ failure to report
constructive dividend income during that year. Finally,
respondent determined that Mr. Speer was liable for additions to
tax for failure to file gift tax returns under section 6651(a)(1)
for the tax years 1985 through 1989.
Because we have held that petitioners did not receive
constructive dividend income during the years in issue and,
likewise, did not make gifts of the license fees to their son,
Richard M. Speer, we hold that petitioners are not liable for any
of the above additions to tax.
Decisions will be entered
for petitioners in docket Nos.
6626-94 and 6628-94.
Decision will be entered
under Rule 155 in docket No.
6627-94.
An appropriate order will be
issued granting petitioners' Motion
to Strike Portions of Brief for
Respondent.
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Last modified: May 25, 2011