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Salih M. Zamzam and Mariam Zamzam, docket No. 2984-97
Penalties
Year Deficiency Sec. 6663 Sec. 6662
1990 $74,453 $36,252 $4,496
1991 $74,390 $44,674 $2,475
1992 $49,635 $37,226 --
1993 $30,703 $23,027 --
1994 $26,707 $16,586 $1,278
Salih M. Zamzam, Inc. (ZMDI), docket No. 3004-97
Penalty
Year Deficiency Sec. 6663
1990 $58,210 $43,657
1991 $72,892 $48,230
1992 $57,117 $38,906
1993 $34,335 $25,379
1994 $24,788 $17,632
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 issues for decision are whether: (1) Petitioners failed to
report income relating to 1990 through 1994; (2) Salih M. Zamzam
M.D., Inc. (ZMDI) paid constructive dividends to the Zamzams from
1990 through 1994; (3) ZMDI was entitled to certain deductions
relating to 1991 through 1994; and (4) petitioners are liable for
fraud penalties.
FINDINGS OF FACT
When their respective petitions were filed, Salih M. Zamzam
and Mariam Zamzam resided, and ZMDI had its principal place of
business, in Grundy, Virginia.
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