- 2 - 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. Respondent determined deficiencies in petitioners’ Federal income taxes and additions to tax as follows: William H. Bruecher III--Docket No. 21530-03S Taxable Deficiency Addition to Tax Year Sec. 6651(a)(1) 1998 $17,602 -0- 1999 $10,077 $504 Bruecher Foundation Services, Inc.--Docket No. 21531-03S Taxable Deficiency Addition to Tax Year Sec. 6651(a)(1) 3/31/20001 $3,792 $948 1Corporate fiscal tax year ending Mar. 31, 2000. After concessions, the issues for decision are: (1) Whether petitioner William H. Bruecher, III received constructive dividends from Bruecher Foundation Services, Inc., in tax years 1998 and 1999 in the amounts of $33,082 and $48,112, respectively; and (2) whether petitioner Bruecher Foundation Services, Inc., is liable for the addition to tax under section 6651(a)(1) in the amount of $948. Background Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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