- 2 - an accuracy-related penalty on Federal income tax for individual petitioners Don and Cecilia Chan as follows:2 Accuracy -related Additions to Tax Penalty Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661 6662(a) 1987 $934,911 --- $46,746 1 $61,350 --- 1988 708,273 $35,414 --- --- 30,992 --- 1989 693,857 --- --- --- --- $14,667 1 50 percent of the interest due on the portion of the underpayment attributable to negligence. Respondent determined deficiencies in and additions to Federal income tax for corporate petitioner Eastimpex for the taxable years ending March 31, 1988 and 1989, as follows: Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1988 $766,321 $38,316 1 $191,580 1989 815,234 --- --- 203,809 1 50 percent of the interest due on the portion of the underpayment attributable to negligence. After concessions, the issues for decision are: (1) Whether certain payments by corporate petitioner Eastimpex to its related supplier were costs of goods sold, (2) whether individual petitioners realized constructive dividends from Eastimpex, (3) whether individual petitioners are liable for additions to tax under sections 6653 and 6661 for 1987 and 1988 attributable to 2 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise designated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011