Robert D. Booth and Janice Booth, et al. - Page 42

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          1990 taxable income was increased by $100,000 and $56,739,                  
          respectively.  The notice stated that N.L. Booth's contribution             
          to the Prime Plan was governed by subpart D.  The notice also               
          stated that N.L. Booth was liable for $6,800 and $4,377 in                  
          accuracy-related penalties under section 6662(a) for the                    
          respective years because its underpayments of income tax were due           
          to substantial understatements.  N.L. Booth filed timely 1989 and           
          1990 tax returns.                                                           
               B.  N.L. Booth's Introduction to the Prime Plan                        
               Barclay D. Schultz was N.L. Booth's insurance agent for the            
          Prime Plan.  On July 17, 1990, Mr. Schultz contacted Prime about            
          N.L. Booth's possible participation in the Prime Plan.  Sixteen             
          days later, Joseph P. Waters, N.L. Booth's certified public                 
          accountant, furnished N.L. Booth with computations of projected             
          earnings from participating in the Prime Plan.  Robert and John             
          Booth (collectively, the Booths), individually and in their                 
          capacity as officers of N.L. Booth, relied upon competent and               
          informed tax and investment advisers before joining the Prime               
          Plan and in reporting the tax ramifications that flowed                     
          therefrom.                                                                  
               C.  N.L. Booth's Adoption of the Prime Plan                            
               N.L. Booth joined the Prime Plan by executing an Adoption              
          Agreement dated and effective as of July 31, 1990, and by                   
          contributing $25,030 to the Trust 37 days later.  N.L. Booth was            
          required to make a remaining contribution of $75,000 to the Trust           




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