- 19 - Respondent determined that the following payments by Beck's Liquors were constructive dividends to Mr. Beck: 1991 1992 1993 Condo association fees 1,276 1,014 980 Insurance-condos, vehicles 3,687 1,866 1,830 Diverted corporate income 74,453 115,133 84,782 Credit card--personal expenses 14,095 14,993 16,193 Auto expense/repairs 10,152 7,294 4,679 Miscellaneous -0- 378 254 Advertising/personal ticket use 200 200 200 Condo utilities 1,098 1,398 1,580 Other personal expenses 15,237 5,239 2,221 Property taxes 1,780 1,750 3,296 Annual meeting expenses 1,461 2,183 1,626 Total 123,439 151,448 117,641 As a result of respondent's determination that Mr. Beck received constructive dividends from Beck's Liquors in each of the years at issue, respondent determined that Mr. Beck underpaid his taxes in 1991, 1992, and 1993, respectively, in the amounts of $28,517.92, $41,509.00, and $30,649.00. OPINION Issues 1, 2, & 3: Whether Beck's Liquors Is Liable for the Fraud Penalty Under Section 6663(a) for Each of the Years at Issue, and Whether Mr. Beck Is Liable for the Fraud Penalty Under Section 6663(a) for Fraudulently Understating His Income on His 1991 Federal Income Tax Return and Under Section 6651(f) for Fraudulently Failing To File Federal Income Tax Returns for 1992 and 1993. Respondent asserts that Beck's Liquors is liable for the fraud penalty under section 6663(a) for each of the years at issue, and that Mr. Beck is liable for the fraud penalty under section 6663(a) for fraudulently understating his income on hisPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011