Bradley K. Morrison - Page 2

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          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.                                      




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