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William D. and Marguerite Barrow
Additions to tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6661
1983 $126,082 $31,520 $7,224 $31,521
1984 9,194 n/a 460 2,298
William D. Barrow
Additions to tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6661
1985 $18,688 $965 $1,245 $4,672
Respondent also determined that petitioners are liable for
additions to tax of 50 percent of the interest due on the
deficiency under section 6653(a)(2) for each year in issue.
After concessions,1 the sole issue that we must decide is
whether petitioner William D. Barrow is liable for income tax on
$175,000 which he received in 1983 and which he contends is
income of a closely held corporation. We hold that he is.
1 Respondent concedes that petitioner Marguerite Barrow is
an innocent spouse as to all adjustments and penalties determined
against her, except for the $3,023 in interest income received in
1983 from her savings accounts, resulting in a deficiency for her
of $704, plus interest as provided by law. Petitioner concedes
all of the other adjustments (such as failure to report in income
legal fees, interest, and stock received as payment for services;
the disallowance of capital gain on the Holiday Isle transaction;
and additions to tax) in this case except whether he was taxable
in 1983 on $175,000 of the $250,000 from the Holiday Isle
transaction.
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