- 11 - Given the fact that BEC "paid" petitioners $925,000 in consideration for property worth $512,000, and that petitioners do not dispute that BEC had enough E+P to characterize the $413,000 difference as a dividend, we sustain respondent's determination that petitioners received a $413,000 dividend on the transfer.3 In reaching our holdings herein, we have considered all arguments made by petitioners for contrary holdings and, to the extent not discussed above, find them to be irrelevant or without merit. To reflect the foregoing, Decisions will be entered under Rule 155. 3 We recognize that the amount of debt canceled by BEC exceeded the amount recited in the contract. Respondent has not attempted to tax this excess amount.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011