- 14 - Dividend History At the suggestion of Bostwick, the board unanimously approved an increase in cash dividends at the February 18, 1994, board meeting. Petitioner’s taxable income, net book income, and dividends paid for years 1995 through 1997 were as follows: Total Taxable Net Book Dividends Dividend Year Income Income Paid Per Share 1995 $390,935 $258,938 $15,665 $10 1996 298,772 208,993 15,665 10 1997 248,978 174,718 14,285 10 Petitioner has a history of making regular, annual dividend payments to its stockholders. Petitioner’s payments of dividends, over the years in issue, averaged 5 percent and 7 percent of petitioner’s taxable and net book incomes, respectively. OPINION As a result of the examination of the years in issue, respondent determined that petitioner’s earnings and profits exceeded the reasonable needs of its business. Respondent determined that the accumulated earnings tax applied to petitioner’s accumulated taxable income of $243,273, $193,328, and $160,433 for 1995, 1996, and 1997, respectively, and determined deficiencies of $94,876, $75,398, and $62,569 for 1995, 1996, and 1997, respectively. Respondent, in accordance with section 534(b), sent to petitioner a notification informing petitioner that a proposedPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011