Robert W. Tschetter - Page 2

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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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