Ricky Schmidt and Suzetta J. Schmidt - Page 2

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          tax and accuracy-related penalties under section 66621 for 1995,            
          1996, and 1997 as follows:                                                  
          Ricky & Suzetta Schmidt, Docket No. 5267-01:                                
                                             Penalty                                  
                    Year      Deficiency     Sec. 6662(a)                             
                    1995      $4,550         --                                       
                    1996      3,715          --                                       
                    1997      2,827          --                                       
          Hillside Dairy, Inc., Docket No. 5268-01:                                   
                    Year                     Penalty                                  
                    Ended     Deficiency     Sec. 6662(a)                             
                    11/30/95   $2,179        $435.80                                  
                    11/30/96    2,698        539.60                                   
                    11/30/97    1,846        369.20                                   
               The issues for decision are:                                           
               (1) Whether amounts paid by Hillside Dairy, Inc. (Hillside             
          Dairy or the corporation), to provide medical care, food, and               
          lodging to its shareholders, Ricky Schmidt (Mr. Schmidt) and                
          Suzetta J. Schmidt (Mrs. Schmidt) (collectively the Schmidts),              
          and their children are (a) constructive dividends, as respondent            
          maintains, or (b) employee medical care expenses and/or                     
          reimbursed employee expenses that are excluded from the Schmidts’           
          gross income and deductible by Hillside Dairy as ordinary and               
          necessary business expenses, as petitioners maintain; and                   



               1All section references are to the Internal Revenue Code in            
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  




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