William Norwalk, Transferee, et al. - Page 3

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          its intangible assets to its shareholders in a liquidation; (2)             
          whether the corporation is liable for depreciation recapture in             
          the amount of $15,643 on the distribution of its tangible assets            
          to its shareholders in a liquidating distribution in 1992; (3)              
          whether Robert and Patricia DeMarta realized a capital gain of              
          $505,935 on the receipt of property from the corporation in a               
          liquidating distribution in 1992; (4) whether William R. Norwalk            
          realized a capital gain of $165,940 on the receipt of property              
          from the corporation in a liquidating distribution in 1992; (5)             
          whether the corporation is entitled to a deduction, reported as             
          consulting fees, of $40,000 for payments to the shareholders in             
          1992; (6) whether Robert DeMarta and William R. Norwalk are                 
          required to report such payments, in the amounts of $23,320 and             
          $16,680, respectively, as dividend income; (7) whether Robert and           
          Patricia DeMarta are liable for an addition to tax under section            
          6651(a)(1)2 and an accuracy-related penalty under section 6662;             
          (8) whether the corporation is liable for an accuracy-related               
          penalty under section 6662; (9) whether William Norwalk is liable           
          for an accuracy-related penalty under section 6662; and (10)                
          whether Messrs. DeMarta and Norwalk are liable as transferees for           
          the corporation's 1992 Federal income tax liability.                        
                                  FINDINGS OF FACT                                    

               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable year in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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