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(2) as to the income tax cases, whether Mrs. Cordes, in
1989 through 1991, and Edmund J. and June J. Cordes (the
Cordeses), in 1992 and 1993, received constructive dividends from
CFC, resulting in additional taxable income to Mrs. Cordes for
1989 through 1991 and to the Cordeses for 1992 and 1993;
(3) as to the income tax case in which CFC is the
petitioner, whether CFC is liable for a civil fraud penalty on an
underpayment of its income tax, pursuant to section 6663, for
1991; and
(4) as to the gift tax cases, whether petitioners therein
made completed gifts of stock in family-owned and closely held
corporations for Federal gift tax purposes.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and two stipulations of agreed adjustments are incorporated in
our findings by this reference.
I. Background
A. Petitioners
The Cordeses were married and resided in Lawton, Oklahoma,
at the time they filed their individual and joint petitions.
Petitioner John J. Cordes (John Cordes) was a resident of Austin,
Texas, at the time his petition was filed. Petitioner Jean Ann
Richard was a resident of Lawton, Oklahoma, at the time her
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