- 2 - FOLEY, Judge: Respondent determined the following deficiencies, addition to tax, and accuracy-related penalties relating to petitioners' Federal income taxes: William L. McCurley and Victoria J. McCurley, docket No. 10499-94 Addition to Tax Year Deficiency Sec. 6661 1988 $43,612 $10,903 1989 9,900 -- 1990 5,600 -- Robert D. Hall and Gayle E. Hall, docket No. 10500-94 Penalty Year Deficiency Sec. 6662 1989 $11,247 $2,249 1990 11,200 2,240 1991 18,468 3,694 William L. McCurley and Victoria J. McCurley, docket No. 6557-95 Penalty Year Deficiency Sec. 6662 1991 $12,664 $2,533 1992 4,473 895 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. The issues for decision are as follows: 1. Whether certain payments made by a corporation to petitioners are loans or constructive dividends. We hold that they are constructive dividends. 2. Whether petitioners, pursuant to section 6662(a), are liable for accuracy-related penalties for negligence in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011