William L. McCurley and Victoria J. McCurley, et al. - Page 2

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               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 the                 




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