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