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utable to the 1994 Virginia Beach property expenses that Delaware
Corporation paid during that year. In Ms. Havens’s notice,
respondent also determined that during 1995 Ms. Havens received
constructive dividends of $23,654 from Delaware Corporation
attributable to the 1995 Virginia Beach property expenses that
Delaware Corporation paid during that year. Respondent further
determined in Ms. Havens’s notice that she is liable for each of
the years 1994 and 1995 for the accuracy-related penalty under
section 6662(a).
Mr. Barber’s Notice of Deficiency
Respondent issued a notice to Mr. Barber (Mr. Barber’s
notice) with respect to his taxable years 1994 and 1995. In that
notice, respondent determined that during 1994 Mr. Barber re-
ceived constructive dividends of $25,569 from Delaware Corpora-
tion, of which (1) $17,807 was attributable to the legal fees
with respect to the Mitchums Creek property that Delaware Corpo-
ration paid during 1994 and (2) $7,762 was attributable to the
1994 child care expenses that Delaware Corporation paid during
that year. In Mr. Barber’s notice, respondent also determined
that during 1995 Mr. Barber received constructive dividends of
$3,321 from Delaware Corporation attributable to the 1995 child
care expenses that Delaware Corporation paid during that year.
Respondent further determined in Mr. Barber’s notice that he is
liable for each of the years 1994 and 1995 for the accuracy-
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