William H. Breucher III - Page 3

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          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 are                      






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