Eric B. Benson, et al. - Page 4

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          for 1994 of $129,902 and $97,426.50, respectively.  See infra p.            
          5, table, note 2.                                                           
               In the notices of deficiency, respondent asserted many                 
          alternatives and whipsaw positions.  For ease of explanation, we            
          address only those issues which we decide.  Additionally, there             
          are numerous computational issues which we omit from our                    
          discussion.  Because of the interconnected nature of these cases,           
          our findings and holdings as to some petitioners will have                  
          ramifications to other petitioners.  As a result, there will be             
          extensive adjustments made by the parties under a Rule 155                  
          computation.                                                                
               After numerous concessions by respondent and petitioners,4             
          the issues remaining for decision are as follows:                           
               1.  Whether petitioners Burton O. and Elizabeth C. Benson              
          (the Bensons) received and failed to report constructive                    
          dividends.  The transactions still at issue for the years and the           
          amounts are listed as follows:                                              










               4Because of their number, a summary of the parties’                    
          concessions is attached hereto and incorporated herein as an                
          appendix.                                                                   





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