- 31 - 11/30/95 11/30/96 11/30/97 Weeldreyer notice of deficiency adjustment for food & lodging provided by Dreyer Farms $12,433 $19,919 $19,573 Food & lodging expenditures 9,908 12,448 12,975 Adjustment for rental value of residence 2,525 7,471 6,598 The Weeldreyers have not shown that the portion of the rent attributable to the farmhouse is less than the amounts for the years at issue, as computed above. We therefore hold that those amounts are properly included in the Weeldreyers’ income for the years at issue. 5. Summary of Adjustments to Weeldreyers’ Income The Weeldreyers’ income from farming is increased by $2,525 in 1995, $7,471 in 1996, and $6,598 in 1997 to reflect the disallowance of deductions for the rental value of the farmhouse. In addition, the following personal expenses paid by Dreyer Farms are included in the Weeldreyers’ income as constructive dividends for the years at issue: 1995 1996 1997 Food $4,406 $7,179 $7,712 Utilities 1,694 2,362 2,235 Landscaping 256 216 -- Remodeling costs 1,729 -- -- Repairs and maintenance -- 82 -- Telephone –- –- 338 Total 8,085 9,839 10,285 Issue 2. Accuracy-Related Penalty Under Section 6662(a) Respondent determined that Dreyer Farms is liable for the accuracy-related penalty under section 6662(a). As pertinent here, section 6662(a) imposes a 20-percent penalty on the portionPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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