- 4 -
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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