- 35 - Reaves because Mr. Reaves endorsed three of them, and the other four are endorsed "S&J Farms" but no one signed them. We disagree. We have found that Mr. Reaves used the proceeds from these checks to buy the livestock as noted on each check. 7. Conclusion We conclude that Mr. and Mrs. Reaves received constructive dividends of $93,410 in 1984, $130,551 in 1985, $270,2007 in 1986, and $222,982 in 1987. C. Mr. and Mrs. Reaves' Liability for Additions to Tax for Fraud 1. Background Respondent determined that Mr. and Mrs. Reaves are liable for the addition to tax for fraud under section 6653(b) for 1984, 1985, 1986, 1987, and 1988. For 1984 and 1985, if any part of a tax underpayment is due to fraud, the addition to tax for fraud under section 6653(b)(1) is 50 percent of the total underpayment of tax, and the addition to tax under section 6653(b)(2) is 50 percent of the interest payable under section 6601, but only with respect to that part of the underpayment that is due to fraud. 7 We have found that Mr. and Mrs. Reaves received constructive dividends of $306,345 in 1986. Respondent determined that Mr. and Mrs. Reaves received constructive dividends of $270,200. We hold that Mr. and Mrs. Reaves received constructive dividends in the amount that respondent determined for 1986.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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