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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Respondent determined deficiencies in the
respective amounts of $60,907, $72,128, $77,072, and $8,243 in
petitioners' 1989 through 1992 Federal income tax, an addition to
tax under section 6651(a)(1) for 1989, and accuracy-related
penalties under section 6662(a) for 1989 through 1992. Following
concessions by both parties, we must decide: (1) Whether
petitioners received constructive dividends in the amounts of
$27,941, $160,780, $53,001, and $15,585 in 1989 through 1992,
respectively, as a result of expenditures made by General
Refining and Smelting Corp. (GRC), Richard J. Spera's (Mr. Spera)
wholly owned corporation; and (2) whether petitioners are liable
for accuracy-related penalties under section 6662(a) for 1989
through 1992. Unless otherwise stated, section references are to
the Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. When the petition was
filed, petitioners resided in Northport, New York. For the years
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