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Edward E. and Constance M. Thorpe
docket No. 23895-95
Accuracy-related Penalty
Year Deficiency Sec. 6662(a)
1990 $8,641 $1,728
1991 7,538 1,508
1992 7,198 1,440
Edward E. Thorpe & Co.
docket No. 23900-95
Accuracy-related Penalty
FYE Deficiency Sec. 6662(a)
6/30/91 $38,803 $7,761
6/30/92 20,862 4,172
After concessions,1 the issues remaining for decision are:
1Petitioner Edward E. Thorpe & Co. (ETCO) concedes that it
is not entitled to: (1) Cost of goods sold/meals expenses of
$4,251 and $4,996 claimed in the fiscal years ending June 30,
1991 and 1992, respectively; (2) a deduction in the amount of
$5,744 for payments made to a pension plan claimed on its
corporate income tax return for the fiscal year ended June 30,
1992; (3) a deduction in the amount of $2,655 for premiums paid
to life insurance companies for insurance on the life of Edward
E. Thorpe claimed on its corporate income tax return for the
fiscal year ended June 30, 1990; (4) office expenses in the
amount of $1,249 claimed on its corporate income tax return for
the fiscal year ended June, 30, 1992; and (5) deductions for
"dues and publications" in the amounts of $3,078 and $2,376 for
the fiscal years ending June 30, 1990 and 1992, respectively.
Petitioners Edward E. Thorpe and Constance M. Thorpe
concede: (1) $2,655 paid by ETCO to life insurance companies is
includable in their income as a constructive dividend in 1990,
and (2) amounts of $3,078 and $2,376 paid by ETCO for "dues and
publications" are includable in their income as a constructive
dividend in the taxable years 1990 and 1992, respectively.
Respondent concedes: (1) ETCO is entitled to a cost of
goods sold/meals deduction in the amount of $4,526 for the fiscal
(continued...)
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