- 2 -
tax and accuracy-related penalties under section 66621 for 1995,
1996, and 1997 as follows:
Waterfall Farms, Inc., Docket No. 5363-01:
Penalty
Year Deficiency Sec. 6662(a)
1995 $184 $37
1996 195 39
1997 2,507 501
Rodney F. and Polly Huber, Docket No. 5365-01:
Penalty
Year Deficiency Sec. 6662(a)
1995 $1,706 --
1996 855 --
1997 2,505 --
The issues for decision are:
(1) Whether amounts paid by Waterfall Farms, Inc. (Waterfall
Farms or the corporation), to provide medical care, food, and
lodging to its shareholders, Rodney F. Huber (Mr. Huber) and
Polly Huber (Mrs. Huber) (collectively the Hubers), and their
daughter are (a) constructive dividends, as respondent maintains,
or (b) employee medical care expenses and/or reimbursed employee
expenses that are excluded from the Hubers’ gross income and
deductible by Waterfall Farms 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