- 2 - Respondent determined deficiencies in petitioners' Federal income taxes for 1992, 1993, and 1994 in the amounts of $3,682, $1,733, and $3,129, respectively, and accuracy-related penalties pursuant to section 6662(a) in the amounts of $736.40, $346.60, and $625.80, respectively. The issues for decision are: (1) Whether petitioners received and failed to report constructive dividends during the taxable years in issue; and (2) whether petitioners are liable for the section 6662(a) accuracy-related penalties for the taxable years in issue. This case was submitted fully stipulated. The stipulations of fact and attached exhibits are incorporated herein by this reference. Petitioners resided in Phoenix, Arizona, on the date the petition was filed in this case. All of the substantive adjustments in the statutory notice of deficiency relate to petitioners' shareholder interests in the Kathy Harvey Trust Corporation (KHTC). Petitioners have operated KHTC as a painting business since its incorporation on May 16, 1984. l. Constructive Dividends The first issue for decision is whether petitioners received and failed to report constructive dividends during the taxable years in issue. Section 61(a) includes in gross income all income from whatever source derived including, but not limited to, dividends. Sec. 61(a)(7).Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011