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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.
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Last modified: May 25, 2011