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Domer L. Ishler
Additions to tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $112,227 $84,170 1 $28,057
1988 396,659 297,494 -- 99,165
1 50 percent of the interest due on $112,227.
20th Century Marketing, Inc.
Additions to tax
Year ended Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
Dec. 31, $118,314 $88,736 1 $29,579
1987
1 50 percent of the interest due on $118,314.
Domer L. Ishler (petitioner) was president and owned all of
the stock of petitioner corporation, 20th Century Marketing, Inc.
(TCM). TCM earned commissions on sales of electronic components
to Chrysler Corp. Petitioner arranged for a Hong Kong
corporation, Camaro Trading Co., Ltd. (Camaro), to receive
commissions which otherwise would have been paid to TCM. The
issues in dispute primarily relate to whether Camaro was paid for
services performed by Camaro, as petitioner contends, or as a
device to avoid taxation of most of that commission income, as
respondent contends.
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