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corporation; held, further, P had constructive
dividend; held, further, all but one deduction
disallowed; held, further, accuracy-related penalties
sustained; held, further, delinquency addition
sustained.
Ira B. Stechel and Thomas J. Fleming, for petitioners.
Daniel O'Brien and Patrick E. Whelan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These cases have been consolidated for
trial, briefing, and opinion. By separate notices of deficiency,
respondent had determined deficiencies in, additions to, and
penalties with respect to the Federal income taxes of petitioners
Valeri Markovski (Markovski) and American Valmar International,
Ltd., Inc. (American Valmar) as follows:
Additions to tax
Petitioner Year1 Deficiency Sec. 6651(a)(1) Sec. 6662(a)
Markovski 1991 $248,662 -- $49,732
1992 499,989 -- 99,998
American 1991 814,158 $203,270 162,832
Valmar 1992 1,125,466 280,827 225,093
1993 190,569 46,485 38,114
1 American Valmar's taxable year is a fiscal year ending
June 30. Markovski is an individual taxpayer whose taxable year
ends Dec. 31.
After concessions, the issues for decision with respect to
American Valmar are:
(1) Whether American Valmar had gross income on account of
receipts of $1,426,653, $1,507,440, and $32,335, during 1991,
1992, and 1993, respectively.
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