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tax and accuracy-related penalties under section 66621 for 1995,
1996, and 1997 as follows:
Ronald & Suzanne Weeldreyer, Docket No. 4676-01:
Penalty
Year Deficiency Sec. 6662(a)
1995 $2,393 --
1996 3,011 --
1997 4,619 --
Dreyer Farms, Inc., Docket No. 4679-01:
Year Penalty
Ended Deficiency Sec. 6662(a)
11/30/95 $2,368 $473.60
11/30/96 3,213 642.60
11/30/97 3,264 652.80
The issues for decision are:
(1) Whether amounts paid by Dreyer Farms, Inc. (Dreyer Farms
or the corporation), to provide medical care, food, and lodging
to its shareholders, Ronald D. Weeldreyer (Mr. Weeldreyer) and
Suzanne Weeldreyer (Mrs. Weeldreyer) (collectively the
Weeldreyers), and their children are (a) constructive dividends,
as respondent maintains, or (b) employee medical care expenses
and/or reimbursed employee expenses that are excluded from the
Weeldreyers’ gross income and deductible by Dreyer 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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Last modified: May 25, 2011