- 6 - immediate family member, before the end of May 2003 without the consent of the Harris County-Houston Sports Authority. In the license agreement, petitioner agreed to use the license himself, rather than to distribute it or the season tickets to others. Because petitioner held title to the seat license until 2003, InsurMark did not benefit from the license in 1999.4 We conclude that InsurMark’s $7,800 payment in 1999 for the permanent seat license was a constructive dividend to petitioners. Decision will be entered for respondent. 4 Petitioners do not contend, and we do not find, that the primary benefit of the permanent seat license ran to InsurMark rather than to them. Cf. Hood v. Commissioner, 115 T.C. 172, 180 (2000).Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011