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.
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