117 T.C. No. 25 UNITED STATES TAX COURT OLIVER K. ROBINSON AND DEBORAH L. ROBINSON, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4428-98, 4429-98, Filed December 19, 2001. 4435-98. R determined that certain expenditures made by P’s wholly owned subch. C corporation (C) constituted constructive dividends to P. At the time that R mailed a notice of deficiency to P, the period for assessment of 1992 fiscal year tax with respect to C had expired, whereas the period for assessment of 1992 tax for P had been extended and had not expired. Because the adjustment to P derives from C’s transactions, P contends that C’s period for assessment should govern R’s ability to make a determination and/or assess tax with respect to P or C. Sec. 6501(a), 1 The following cases have been consolidated for purposes of trial, briefing, and opinion: Pak West Airlines, Inc., docket No. 4429-98; and Career Aviation Academy, Inc., docket No. 4435- 98.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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