Donald C. Richardson and Rita M. Allaire - Page 2

                                        - 2 -                                         

          litigation and administrative costs under section 74301 and Rules           
          230, 231, and 232.  These related cases have been consolidated              
          for the purpose of considering these motions.                               
               On March 13, 1997, respondent issued statutory notices of              
          deficiency to petitioner Paige Communications Corporation of                
          Louisiana (PCCL) and to petitioners Donald C. Richardson and Rita           
          M. Allaire2, husband and wife, for the taxable year ended 1993.             
          Deficiencies in income tax and penalties were determined as                 
               Taxpayer       Deficiency     Sec. 6663(a)   Sec. 6662(a)1             
          Richardson/Allaire  $12,781             $9,586         -0-                  
          PCCL                104,002             78,002         -0-                  
               1  The negligence penalty was imposed as an alternative to             
          the fraud penalty.                                                          
               Respondent determined that petitioners received income in              
          the form of constructive dividends from PCCL in the amount of               
          $47,086.  Respondent determined that the constructive dividends             
          consisted of (1) PCCL corporate income in the amount of $14,443             
          diverted for petitioners' personal use; (2) improvements to                 
          petitioners' residence paid for by PCCL in the amount of $8,549;            

               1    Unless otherwise indicated, section references are to             
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           
               2    "Petitioners" will collectively refer to petitioners              
          Richardson and Allaire.  "Petitioner" will refer to petitioner              
          Donald C. Richardson individually.                                          

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011