Stephen M. and Rebecca A. Kerns - Page 2

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          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 season              









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