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Docket No. 10508-95
Year Deficiency
1988 $ 0
1989 4,796
Docket No. 10509-95
Additions to Tax and Penalty
Year Deficiency Sec. 6653(a) Sec. 6661 Sec. 6662
1988 $15,059 $753 $3,560 ---
1989 79,636 --- --- $15,927
Unless otherwise indicated, 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.
After concessions by the parties, the issues for decision
are: (1) Whether petitioner Allied Marine Systems, Inc.
(Allied), is entitled to reductions in gross income and to
additional expenses for 1988 and 1989; (2) whether petitioner
Richard M. Gibbons (petitioner) is entitled to additional
miscellaneous itemized deductions in 1988; (3) whether petitioner
received constructive dividends or wages from Allied's paying his
personal expenses in 1988 and 1989; (4) whether petitioner can
exclude gain under section 121 and defer gain under section 1034
in 1989; and (5) whether petitioner is liable for the additions
to tax and penalty as determined by respondent.
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Last modified: May 25, 2011