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Of the reported compensation, Robert Booth received $92,600,
$139,600, $228,000, $119,746, and $122,000 during his 1989
through 1993 taxable years, respectively, and John Booth received
$85,300, $134,800, $224,800, $314,946, and $117,200 during the
same respective years.
R&J Booth filed timely joint 1990 and 1991 Federal income
tax returns. On November 16, 1993, the Commissioner mailed them
a notice of deficiency reflecting a determination that R&J
Booth's taxable income for 1990 and 1991 was increased by $46,000
and $26,100, respectively, on account of taxable transfers of
property from N.L. Booth under section 83. The notice also
stated that R&J Booth were liable for $3,036 and $1,784 in
accuracy-related penalties under section 6662(a) for the
respective years.
On the same day, the Commissioner mailed to J&D Booth a
notice of deficiency reflecting her determination that J&D
Booth's 1990 and 1991 taxable income was increased by $54,000 and
$30,639, respectively, on account of taxable transfers of
property from N.L. Booth under section 83. J&D Booth had timely
filed a joint Federal income tax return for each of these years.
The notice also stated that J&D Booth were liable for $3,564 and
$2,053 in accuracy-related penalties under section 6662(a) for
the respective years.
The Commissioner also mailed a notice of deficiency to N.L.
Booth on that date, reflecting a determination that its 1989 and
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