- 2 - Penalty Year Deficiency Sec. 6662(a) 1999 $87,780 $17,556 2000 4,075 -- After concessions,2 the issues for decision are: (1) Whether payments made on behalf of petitioner or disbursements directly to petitioner by Caspian Consulting Group, Inc., during 1999 and personal charges petitioner made on a company credit card in 2000 were constructive dividends; and (2) whether petitioner is liable for an accuracy-related penalty under section 6662(a)3 for 1999. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Belmont, California, at the time he filed his petition. Petitioner owned 40 percent of the outstanding stock of Caspian Consulting Group, Inc. (Caspian). Petitioner provided “technical services and expertise to * * * [Caspian’s] service and support teams.” Nariman Teymourian (Mr. Teymourian) owned the remaining 60 percent of the Caspian stock. 2 Petitioner conceded that he had additional interest income of $227 in 2000. 3 Unless otherwise stated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011