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Year Deficiency Accuracy-Related Penalty
1996 1$15,672 $3,134.40
1997 115,832 3,166.40
1The deficiency determined by respondent for each year included a
deficiency of $120 in Federal excise tax under sec. 4973(a).
The issues remaining for decision2 are:
(1) Do payments during each year at issue by Burien Nissan,
Inc. (Burien Nissan), to Kenneth Stanford (Mr. Stanford) consti-
tute constructive dividends to petitioner Herbert L. Whitehead
(Mr. Whitehead) for each such year? We hold that they do.
(2) Should the determinations in the notice of deficiency
(notice) to increase petitioners’ income for each year at issue
with respect to their respective uses of certain Burien Nissan
automobiles during each such year be sustained? We hold that
they should.
(3) Are petitioners entitled to a deduction for each year
at issue for mortgage interest and property taxes relating to
certain real property located in Kirkland, Washington? We hold
that they are not.
(4) Are petitioners entitled to a deduction for 1996 for
certain contributions to an individual retirement account (IRA)
in the name of petitioner Jennifer L. Whitehead (Ms. Whitehead)
in excess of the amount conceded by respondent? We hold that
2Certain computational issues for the years at issue also
remain, resolution of which flows automatically from our resolu-
tion of the issues that we address herein.
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Last modified: May 25, 2011