Waterfall Farms, Inc. - Page 2

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          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.                                  




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