- 6 -
did not require a repayment schedule for such “advances”.
Bruecher Foundation did report the “advances” as a liability on
each of its Forms 1120, U.S. Corporation Income Tax Return,
Schedule L, Balance Sheets per Books for the fiscal tax years
1998 and 1999.
In the notice of deficiency issued to Mr. Bruecher,
respondent determined that for tax years 1998 and 1999 he
received constructive dividends in the amounts of $33,082 and
$48,112, respectively. These amounts were computed by using
figures in the “Advance - Bruecher, WM.” account adjusted as
follows:
Tax Year 1998
Date Amount
04/01/1998 - Beginning balance $77,318
12/31/1998 - Ending balance 120,325
Difference - Increase in balance 43,007
Corporate expenses paid by
Mr. Bruecher1 9,925
Net constructive dividends 33,082
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Last modified: May 25, 2011