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All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated. The issues for decision are:1
(1) Whether any portion of improvements made by Goshorn
Construction & Pipeline, Inc. (Goshorn), petitioner's wholly
owned corporation, to property owned by petitioner and leased to
Goshorn in 1987 constituted a constructive dividend to petition-
er.
(2) Whether any portion of disbursements made to or on
behalf of petitioner by Goshorn during the years 1987 through
1990, constituted dividends to petitioner.
(3) Whether, pursuant to section 6651(a), petitioner is
liable for additions to tax for the tax years 1987, 1988, and
1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are incorpo-
rated herein by this reference. At the time the petition was
filed, petitioner resided in Arvada, Colorado. Tangaree Weigel,
not a party to this case, was petitioner's wife for all the years
at issue.
1In the statutory notice of deficiency, respondent deter-
mined that petitioner did not have a sufficient basis under sec.
1366(d)(1) to deduct S corp. losses of $215,205 in the 1989 tax
year. Petitioner conceded this determination.
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