- 4 - penalties for negligence or disregard of rules or regulations as follows: MI is liable with respect to the TMI expenses deduction as disallowed, and S is liable with respect to the excess TMI expenses constructive dividend and the constructively received interest income. Robert E. Dallman, Vincent J. Beres, and Robert J. Misey, Jr., for petitioners. Christa A. Gruber, J. Paul Knap, and Michael Calabrese, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: These cases were consolidated upon motion of the parties for purposes of trial, briefing, and opinion. Respondent determined deficiencies and section 6662(a)1 accuracy- related penalties with respect to petitioners’ income tax and, by amendment to answer, increased those deficiencies as follows: Menard, Inc., docket No. 673-02 Accuracy-related penalty TYE Jan. 31 Deficiency sec. 6662(a) 1998 $8,966,233 $430,414 1All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Monetary amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011