- 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