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Docket No. 9146-93
Addition to Tax
Tax Year Deficiency Sec. 6661(a)
1987 $63,128 $22,734
Docket No. 9171-93
Addition to Tax
Tax Year Deficiency Sec. 6661(a)
1987 $88,370 $22,093
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the issues remaining for decision are as
follows: (1) Whether the fair market value (FMV) of certain
real property sold to the Laniers by their wholly owned
Corporation exceeded its purchase price; and (2) whether the
Laniers received a constructive dividend in the amount of $13,000
as a result of the Corporation's transfer of that sum to their
son's election campaign committee.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and attached exhibits are
incorporated herein by this reference. The Corporation was
domiciled in Youngsville, Louisiana, at the time it filed its
petition. The Laniers were married and resided in Youngsville,
Louisiana, when they filed their petition.
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