Robert C. Geib - Page 2




                                         - 2 -                                          
                         Excise Taxes                   Addition to Tax                 
          Year      Sec. 4975(a)    Sec. 4975(b)        Sec. 6651(a)(1)                 
          1988           $409            --                   $102                      
          1989           901             --                   225                       
          1990      1,897                --                   474                       
          1991      3,160                --                   790                       
          1992      4,809                --             1,202                           
          1993      6,660                --             1,665                           
          1994      8,737                --             1,311                           
          19981          --         $174,761                  --                        
               1 For the taxable period ending January 15, 1998.                        
               Unless otherwise indicated, all section references are to                
          the Internal Revenue Code in effect for the years in issue, and               
          all Rule references are to the Tax Court Rules of Practice and                
          Procedure.  After concessions, the issue is whether respondent is             
          precluded from assessing the deficiencies and additions.                      
                                      Background                                        
               The parties submitted this case fully stipulated pursuant to             
          Rule 122.  When the petition was filed, petitioner resided in                 
          Akron, Ohio.  During 1988 and 1990, petitioner was married.                   
               During 1988 through 1990, petitioner was president,                      
          director, and majority stockholder (i.e., owner of at least 51                
          percent of the stock) of Cotter Merchandise Storage Co. (the                  
          company).  The company maintained the Cotter Merchandise Storage              
          Co. Defined Benefit Pension Plan (the plan), which met the                    
          requirements of section 401.  Petitioner was a trustee and                    
          participant of the plan.                                                      








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