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00174. We hold that it may not, and that the $1,254 payment is a
constructive dividend to petitioner.2
9. Whether petitioners are liable for the accuracy-related
penalty for negligence under section 6662(a). We hold that they
are to the extent described below.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioner and Mrs. Boler (the Bolers) are married and
resided in Mississippi when they filed the petition.
AIM’s principal place of business was in Mississippi when
the petition was filed. AIM was incorporated in 1990.
Petitioner has been the sole shareholder of AIM since December
31, 1990. AIM began doing business in February 1992. AIM is a
calendar-year, accrual basis taxpayer. The Bolers were the only
members of AIM’s board of directors from 1992 through the date of
trial. The Bolers sometimes paid AIM’s expenses with their
personal funds and received reimbursements from AIM. Mrs. Boler
maintained records of the amount of reimbursements AIM owed to
the Bolers.
2 Respondent concedes that the $600 and $480 payments are
not constructive dividends.
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