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Unless otherwise noted, 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.
FINDINGS OF FACT
Introduction
Frank Wheaton is married to Mary Wheaton, and they resided
in Millville, New Jersey, at the time their petitions in these
cases were filed. They made joint returns of income for the
taxable (calendar) years 1979 through 1990.
Dorchester is a New Jersey corporation. It is engaged in
shipbuilding and repair. Dorchester’s mailing address was in
Dorchester, New Jersey, at the time its petition in this case was
filed. Dorchester is a calendar-year taxpayer.
At all times relevant to the issues in these cases, Frank
Wheaton was the sole shareholder of Dorchester. Frank Wheaton
has been the president of Dorchester since at least 1991.
The Scheduled Trial
By order of the Chief Judge dated January 19, 1995, the
cases at docket Nos. 20515-93, 20572-93, and 27121-93 (the 1993
docketed cases) were assigned to Judge James S. Halpern for
disposition. By order dated February 14, 1995, the 1993 docketed
cases were consolidated and set on a special trial calendar to
commence in Philadelphia, Pennsylvania, on October 30, 1995. By
order dated October 19, 1995, the 1993 docketed cases were set
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