- 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