- 6 - Robert Hinman, C.P.A., of Stanfield & O’Dell, P.C., prepared CFC’s, ECI’s, the Cordeses’, John Cordes’s, and Eddy Ben Cordes’s tax returns for the years at issue. Michael Mayhall of Godlove, Mayhall, et al., Attorneys, prepared Jean Ann Richard’s tax returns for the years at issue. II. Constructive Dividends Respondent determined that one or more of the individual petitioners received constructive dividends in the years at issue from CFC and/or ECI. Specifically, respondent determined that the individual petitioners in each docket4 received the following constructive dividends from the following corporations: Source of Distribution ECI 1994 1995 Diversion of checks from unidentified loans $88,225 $16,000 Diversion of tag refunds 57,609 55,088 Excess payoffs 3,826 28,514 Cash distributions to Mr. Cordes -0- 600,000 Total from ECI 149,660 699,602 4Respondent claims that the constructive dividends arose from certain transactions between CFC and/or ECI and the members of the Cordes family, wherein the shareholder(s) received economic benefit(s) from the corporation or corporations, without an expectation of repayment. Because respondent was initially unable to determine which individual petitioner received each constructive dividend, respondent determined, to protect the Government’s interest, that each of the individual petitioners received the constructive dividend in full.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