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Timothy Dean Strong--docket No. 821-01
In the alternative
Penalty Penalty Addition to Tax
Year Deficiency Sec. 6663 Sec. 6662 Sec. 6651(a)(1)
1990 $9,768 $7,326.00 $1,953.60 $2,442.00
1991 11,185 8,388.75 2,237.00 2,796.25
1992 19,794 14,845.50 3,958.80 4,948.50
1993 31,567 23,675.25 6,313.40 7,891.75
1994 6,613 4,959.75 1,322.60 N/A
Strong Construction Co., Inc.--docket No. 2048-01
In the alternative
Addition to Tax Addition to Tax
Year Deficiency Sec. 6651(f) Sec. 6651(a)(1)
1990 $6,257 $4,693 $1,564
1991 6,925 5,194 1,731
1992 12,871 9,653 3,218
1993 25,783 19,337 6,446
1994 5,090 3,818 N/A
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect during the taxable years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The issues for decision are:
1. Whether petitioner Strong Construction Co., Inc. (SCC),
should be recognized as a taxable entity. We hold SCC is a
taxable corporate entity;
2. whether SCC had additional income from sales of houses
it constructed during the years 1990-94 (the years at issue) and
from unidentified taxable sources, as established on the basis of
deposits to petitioner Timothy Dean Strong’s (Mr. Strong) joint
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