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Background
Petitioner Howard E. Clendenen, Inc. (the corporation), is a
corporation with a mailing address in Des Moines, Iowa. On May
22, 1996, respondent sent the corporation a notice of deficiency
determining the following deficiencies in the corporation’s
Federal income taxes:
Tax Year Ended Deficiency
6/30/87 $10,273
6/30/88 32,607
6/30/89 13,775
In this notice of deficiency, respondent determined that the
corporation’s employee stock ownership plan (the plan) was a
nonqualified plan because it did not meet the requirements of
section 401(a). On August 21, 1996, the corporation filed a
petition with the Court alleging error in respondent’s
determination that the plan is nonqualified.
On May 22, 1996, respondent sent petitioner Howard E.
Clendenen (Mr. Clendenen) a notice of deficiency determining
deficiencies in his Federal income taxes, an addition to tax, and
an accuracy-related penalty as follows:
Addition to Tax Penalty
Tax Year Deficiency Sec. 6653(a)(1) Sec. 6662(a)
1987 $13,641 — —
1988 34,071 $1,704 —
1989 1,187 — $237
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Last modified: May 25, 2011