- 2 -
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
We must decide the following issues:
(1) Whether the transfer of Las Colinas Ranch from Paz Gas
Corporation to petitioner, the controlling shareholder, was a
sale or a dividend. We hold that the transfer was a dividend.
(2) Whether petitioner is liable for the accuracy-related
penalty as determined by respondent. We hold that petitioner is
so liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts,
supplemental stipulation of facts, and attached exhibits. At the
time of filing the petition, petitioner resided in Cuero, Texas.
Background
Petitioner's formal education consisted of secondary school
through approximately ninth grade and 2� years of college. After
college, he took a job with Houston Natural Gas, and about 16
years later became president of Houston Pipeline Company.
Following this, in 1989 or 1990, he took a position as president
and chief operating officer of Tejas Gas Corporation. Petitioner
formed Paz Gas Corporation (Paz) in 1988, and he was the sole
shareholder.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011