Eddie Cordes, Inc., et al. - Page 6




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               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.                                 




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