Richard J. and Carol C. Spera - Page 2

                                        - 2 -                                         




                       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           





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