Lynnda Speer, Donor, et al. - Page 33

                                       - 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