Oliver K. Robinson and Deborah L. Robinson, et al. - Page 5




                                        - 5 -                                         
         9, 1997, respondent issued a notice of deficiency to the                     
         Robinsons for their 1992 and 1993 individual income tax years.               
         In that notice, respondent determined that the Robinsons had                 
         constructive dividend income of $115,888 and $216,685 that was               
         attributable to Career’s fiscal years ended July 31, 1992 and                
         1993.  The constructive dividends were imputed to Mr. Robinson,              
         as 100-percent owner of Career, and derived from various                     
         nonbusiness expenses of the Robinsons that were paid by the                  
         corporation.4  Payment of these personal items of the Robinsons              
         was not reported as income by them or as loans to shareholders on            
         Career’s books.                                                              
              Respondent also determined that the Robinsons were liable               
         for self-employment tax in the amounts of $5,928 and $4,383 for              
         1992 and 1993, respectively.  Those adjustments were based on                
         respondent’s determination that Mr. Robinson received corporate              
         compensation during 1992 and 1993 ($31,015 in each year) which               
         had not been reported as self-employment income.  The Robinsons              
         did report the $31,015 on each of their 1992 and 1993 returns,               
         but reported the amount as income from “forgiveness of debt”.                
         Career’s books and records do not reflect any specific                       



               4 With the exception of the $39,824 constructive dividend              
          remaining in controversy (which involves payments of the                    
          Robinsons’ expenses during the first half of Career’s fiscal year           
          ended July 31, 1992) the parties have reached agreement regarding           
          the remainder of the Robinsons’ constructive dividend issues for            
          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