Charles B. and Teresa A. Thompson, et al. - Page 2

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          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure, unless otherwise indicated.  In docket No. 5220-95,              
          respondent issued a notice of final S corporation administrative            
          adjustment (FSAA) to Douglas J. Von Allmen, tax matters person of           
          State Supply Warehouse Co. (State Supply), setting forth the                
          following adjustments with respect to State Supply's 1989 taxable           
          year:                                                                       
               Item                  FSAA Adjustment   Amount in Dispute              
          Sales promotion          $7,065              -0-                            
          Covenant not to compete       673,560        $673,560                       
               During the 1990 tax year, State Supply was an S corporation            
          not subject to the unified audit and litigation procedures of the           
          Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.           
          97-248, sec. 402(a), 96 Stat. 324, 648.  All of respondent's                
          adjustments to State Supply flowed directly through to its                  
          shareholders' tax returns. Respondent determined the following              
          deficiencies in, and penalty on, petitioners' Federal income tax:           
          Charles B. and Teresa A. Thompson--docket No. 5219-95                       
               Year           Deficiency                                              
               1990           $8,638                                                  
          Douglas J. and Linda L. Von Allmen--docket No. 16787-95                     
                                             Accuracy-related Penalty                 
               Year           Deficiency             Sec. 6662(a)                     
               1990           $88,319                  $17,664                        






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