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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.
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