- 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 follows: Penalties 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