- 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Robert W. Tschetter, Docket No. 5271-01: Year Deficiency 1995 $1,185 1996 1,136 1997 1,095 Wolf Creek Farm, Docket No. 5272-01: Penalty Year Deficiency Sec. 6662(a) 1995 $1,190 $238 1996 1,234 1247 1997 992 1198 1 Amounts are rounded to the nearest dollar. The issues for decision are: (1) Whether amounts paid by Wolf Creek Farm, Inc. (Wolf Creek Farm or the corporation), to provide medical care, food, and lodging to Robert W. Tschetter (Mr. Tschetter), one of its shareholders, are (a) constructive dividends, as respondent maintains, or (b) employee medical care expenses and/or reimbursed employee expenses that are excluded from Mr. Tschetter’s gross income and deductible by Wolf Creek Farm 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.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