- 17 - reported $420 and $2,094 of dividend income for 1991 and 1992, respectively. The dividend income reported for 1991 and 1992 was not attributable to any distributions from WVI. Notice of Deficiency In the notice of deficiency, respondent determined that the fair market value of the stock awarded to Dr. Gow on February 16, 1989, was $1,600,000, and the fair market value of the stock awarded to her on February 15, 1990, was $800,000. After the issuance of the notice of deficiency, respondent’s valuation experts revalued the stock awards at $2,142,313 and $597,353 at their respective valuation dates. Respondent also determined that petitioners received constructive dividends from WVI for 1989, 1990, 1991, and 1992 in the amounts of $305,072, $395,225, $341,521, and $323,281, respectively. By amendment to answer, respondent increased the amount for 1991 to $479,844. In his posttrial brief, respondent concedes that certain expenses paid by WVI in 1989-92 do not constitute constructive dividends to petitioners. On the basis of respondent’s redetermination of the values of the stock awards and the increase in the amount of the 1991 constructive dividend, the deficiencies asserted for 1989 and 1991 increased to $877,054 and $153,214, respectively.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011