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Roland and Virginia Fox
Addition
to tax Penalty
Year Deficiency Sec. 6651 Sec. 6662(a)
1989 $16,298 -- $3,260
1992 47,758 -- 3,848
1993 62,892 $15,473 12,578
Prindle International Marketing, UBO
Keyus Group - Trustee
Addition
to tax
Year Deficiency Sec. 6651
1992 $32,508 $8,127
1993 54,068 13,517
We must decide the following issues:
1. Whether petitioners are entitled to have Roland Fox's
diary admitted into evidence or to use it during his testimony to
refresh his recollection where petitioners had not exchanged it
as required by the Court's standing pretrial order or produced it
in response to a discovery request. We hold that they are not.
2. Whether Prindle International Marketing is a sham. We
hold that it is, and we do not recognize it for Federal income
tax purposes.
3. Whether petitioners Roland and Virginia Fox may deduct
$100,000 as contributions to a welfare benefit plan in 1992. We
hold that they may not.
4. Whether respondent's determination that petitioners
Roland and Virginia Fox received $2,237 in unreported interest
income in 1993 was arbitrary. We hold that it was.
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