- 2 -
Henry C. Boler and Sherry M. Boler
Accuracy-related
penalty
Year Deficiency sec. 6662(a)
1994 $1,563 $313
1995 945 189
1996 630 126
AIM Construction, Inc.
Accuracy-related
penalty
Year Deficiency sec. 6662(a)
1994 $10,417 $2,083
1995 5,132 1,026
1996 6,888 1,378
AIM Construction, Inc. (AIM), is petitioner’s wholly
owned corporation.1
After concessions, the issues for decision are:
1. Whether amounts AIM paid to Henry C. Boler (petitioner)
($16,599 in 1994, $21,460 in 1995, and $9,640 in 1996) are
interest, as petitioners contend, or constructive dividends, as
respondent contends. We hold that those payments are
constructive dividends.
2. Whether AIM may deduct $14,900 in 1996 as a bad debt.
We hold that it may.
1 Section references are to the Internal Revenue Code in
effect for the applicable years. Rule references are to the Tax
Court Rules of Practice and Procedure.
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