Ronald D. Ciaravella - Page 3

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               (2) Whether and to what extent, for the calendar years 1992            
          and 1993, gross receipts of Ronald D. Ciaravella (Mr. Ciaravella)           
          in the name of his sole proprietorship, Innovative Advertising              
          (Innovative), are includable in his gross income as constructive            
          dividends received from Icarus.                                             
               (3) Whether Mr. Ciaravella is entitled to deductions for               
          expenditures claimed as business expenses on the Innovative                 
          Schedules C for the years 1992 and 1993.                                    
               (4) Whether Mr. Ciaravella is liable for the accuracy-                 
          related penalty under section 6662(a) for 1993 due to negligence            
          or disregard of rules or regulations.                                       
               We disallow part of the race car expenditures claimed as               
          deductions by Icarus, but hold that no amounts paid to Mr.                  
          Ciaravella through Innovative are includable in Mr. Ciaravella's            
          income as constructive dividends.  We further hold that Mr.                 
          Ciaravella is not entitled to deduct business expenses on the               
          Innovative Schedules C, thereby disallowing the net losses                  
          claimed thereon.  Finally, we hold that Mr. Ciaravella is liable            
          for the accuracy-related penalty for 1993 in an amount equal to             
          20 percent of the underpayment to be determined under a Rule 155            
          computation.                                                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are incorporated            
          herein by this reference.                                                   





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