-2- Accuracy-Related Penalties Year Deficiency Sec. 6662 1989 $210,819 $42,164 1990 125,150 25,030 1991 90,018 18,004 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, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. After concessions,1 the issues for decision are: (1) Whether petitioner received taxable distributions from Carl E. Jones Development, Inc. (Development), of $307,976, $261,591, and $224,827, in 1989, 1990, and 1991, respectively. We hold petitioner received distributions from Development the character and amounts of which are set out below. (2) Whether petitioner had sufficient basis in Development's indebtedness to him to deduct pass-through losses of $163,487 and $21,022 in 1990 and 1991, respectively. We hold he did not. (3) Whether petitioners had constructive dividend income of $80,051 in 1989 from either INI, Inc. (INI), or Spalding Partners, Ltd. (Spalding). We hold they did not. (4) Whether petitioner received constructive 1 Petitioners reported $66,299 of taxable interest income on their return for 1989. Prior to trial, petitioners conceded that the correct amount is $80,120. Petitioner reduced his shareholder loan account balance with Carl E. Jones Development, Inc., for a payment of $54,369 that he made in 1990; respondent concedes on brief the allowance of this payment.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