- 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