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Penalty
Docket No. Year Deficiency Sec. 6662(a)
4428-98 1992 $31,319 $6,264
1993 84,739 16,948
4429-98 1994 79,031 15,806
4435-98 1993 186,991 37,398
1994 110,602 22,120
After concessions,3 the issues remaining for our
consideration are: (1) Whether respondent was barred from
determining constructive dividend income for the Robinsons from
their wholly owned corporation because the period for assessment
of a deficiency in the corporation’s income tax had expired; (2)
whether the Robinsons are liable for self-employment taxes of
$5,928 for 1992 and $4,383 for 1993; and (3) whether petitioners
are liable for section 6662 penalties.
FINDINGS OF FACT
At the time their petitions were filed, Oliver and Deborah
Robinson were married and resided in Oakdale, California. The
principal place of business of the corporate petitioners, Career
Aviation Academy, Inc. (Career), and Pak West Airlines, Inc. (Pak
West), was Oakdale, California, at the time their petitions were
filed. Career was wholly owned by Mr. Robinson, and Pak West was
wholly owned by Mrs. Robinson. Both corporations were entities
subject to tax (C corporations). Career reported income on the
3 The parties’ stipulations of facts and settled issues are
incorporated by this reference.
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