Robert T. and Mary F. Gow - Page 17




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          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.                             










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