- 2 - corporation in 1999 for a permanent seat license allowing him to buy six season tickets to Houston Texans football games was a constructive dividend to petitioners. We hold that it was. References to petitioner are to Stephen M. Kerns. Section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties submitted this case fully stipulated under Rule 122. A. Petitioners and InsurMark Petitioners resided in Houston, Texas, when they filed their petition. In 1998 and 1999, petitioners owned 100 percent of the stock of InsurMark, Inc., a corporation which sells annuities to insurance and financial agents. Petitioner was the president and chief executive officer of InsurMark, Inc., in 1998 and 1999 and is currently its president. B. The Permanent Seat License On December 31, 1999, petitioner submitted an application to the Harris County-Houston Sports Authority for a permanent seat license under which petitioner had the right to buy six seasonPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011