- 2 - I.R.C., are sustained, subject to recomputation under Rule 155. Mike E. Jorgensen, for petitioners. Charles Baer, for respondent. MEMORANDUM OPINION NIMS, Judge: Respondent determined the following deficiencies, additions to tax, and accuracy-related penalty with respect to the Federal income tax of petitioners, Raymond K. and Minerva R. Mason, for the taxable years 1987, 1988, and 1989: Additions to Tax Penalty Year Deficiency Sec. 6661 Sec. 6662(a) 1987 $38,236 $9,559 -- 1988 36,662 9,166 -- 1989 -- -- 1$5,927 ______________ 1 This figure is equal to 20 percent of the underpayment of tax previously assessed. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the remaining issues for decision are: (1) Whether petitioners received below-market demand loans from their closely held corporation such that dividends may be imputed to them in 1987 and 1988 in the amount of the forgone interest pursuant to section 7872; and (2) whether petitioners are liablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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