- 3 - in Chapel to constitute control within the meaning of section 368(c), as required by section 355(a)(1)(D). The notice of deficiency sent to petitioners determined that, in the event it is decided that Mr. Pulliam did not receive dividends of $789,500 from Homes, Mr. Pulliam received $40,000 in 1992 as a downpayment on an installment sale of 49 percent of his stock in Chapel, which petitioners did not report on their Federal income tax return for that year.3 This alternative determination was not placed in issue by petitioners. Likewise, petitioners did not allege errors in their petition with respect to the disallowance of a personal exemption deduction, an adjustment to itemized/standard deductions, and the assertion of an accuracy-related penalty under section 6662(a). FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and supplemental stipulation, together with attached exhibits, are incorporated herein by this reference. Clark D. Pulliam and Janis L. Pulliam (petitioners) resided in Robinson, Illinois, at the time they filed their petition in this case. 3 According to Mr. Pulliam's testimony, the $40,000 was omitted from petitioners' Federal income tax return, but it was later reported and an advance payment was made on the deficiency determined for 1992.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