- 7 - Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment, enclosed with the July 29 letter, KSCI was treated as an S corporation. The Form 870-AD reflected adjustments to increase the taxable income of KSCI by $48,864 and $49,092 for 1992 and 1993, respectively. Because KSCI was treated as an S corporation, there was no tax imposed on KSCI as a result of the adjustments. The Form 870-AD reflected adjustments to increase the taxable income of petitioner and his wife by $42,755 and $42,803 for 1992 and 1993, respectively. As a result of the increases in taxable income, the Form 870-AD set forth increases in the Chans’ tax liabilities of $9,477 and $9,868 for the respective tax years. On August 4, 1997, Mr. and Mrs. Chan executed the Form 870-AD. On August 21, 1997, Mr. Peter sent a letter to petitioner reciting approval of the settlement of examination changes. In the Appeals Transmittal and Supporting statement, dated August 21, 1997, Mr. Peter explained that it was an error for the examining agent to treat KSCI as a C corporation in the examination. Mr. Peter concluded that KSCI was not a personal holding company, and that absent evidence to the contrary, petitioner would not be treated as having received constructive dividends from KSCI in 1992 and 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011