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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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Last modified: May 25, 2011