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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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