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Tax Year
Description 1988 1989 1990 1993 1994
ERG-Recreation acct.–- –- –- $8,000 $2,698
Transfers ERG to NPI $180,000 $483,098 –- 3,600,000 160,063
143 Alice Lane –- –- $336,500 –- –-
Prop. taxes Alice Ln.–- –- –- 3,879 8,196
–-96,749 –-
Check ref: Carroll –- –- –-
Automobile deductions9,465 10,624 8,67614,808 14,723
Charitable deduction–- –- –- 50,000 –-
Excess rent--Stanford1–- –- 240,067 46,560 63,444
Rent--Lowell plant 31,850 29,400 29,40031,020 341,376
Director’s fees
Elizabeth Benson –- 3,000 12,000 12,000 12,000
–-3,000 11,000
Related parties –- 30,000 25,000
Esther Benson check –- –- –- –- 12,000
Townsend check –- –- –- –- 15,000
Travel expenses –- –- –- –- 6,690
Legal expenses –- –- –- –- 4,159
Employee relations –- –- –- –-4,027
Total 221,315 625,871 437,643 3,796,267 369,376
1The record and briefs contain inconsistencies with respect to
respondent’s determinations for the Stanford and Lowell plants. Indeed,
generally, the notices of deficiency list the amounts stated above for
Stanford as that for Lowell, and vice versa. For example, on one page of the
Bensons’ notice of deficiency for 1994, the adjustment for “Excess rents for
Stanford plant” is listed as $41,736 and for “ERG’s payments for Lowell plant”
as $35,316. On the very next page, the excess rent for Stanford is listed as
$35,316 and for Lowell as $41,736. Respondent’s answers, amendments thereto,
and brief mimic the amounts stated above. We assume a clerical error and
assign no substantive significance to this error.
2On brief, respondent explained that he amended his answers in docket
Nos. 12967-00 and 14171-01, which amendments caused respondent to assert
increased deficiencies for the Bensons, for tax years 1990 and 1994. See
supra p. 3, tables, notes 1 & 2. However, for 1993 his amendment caused a
decrease in the amount determined; respondent determined in the notice of
deficiency that the Bensons failed to report $48,758 in rent for the Stanford
plant. See supra p. 3, table, note 3.
3Clearly, there is a clerical error in the amount stated in respondent’s
brief, $41,376, as the amount listed in the notice of deficiency is $41,736.
2. whether the Bensons received and failed to report other
income. The transactions still at issue for the years and in the
amounts are as follows:
Tax Year
Description 1988 1989 1990 1993 1994
Dividend income –- –- –- –- $1,072
–-–-
Discharge debt –- –- –- 188,291
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Last modified: May 25, 2011