Timothy Dean Strong - Page 3

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          bank account with SCC.  We hold with certain specific exceptions            
          that SCC did have the additional income determined by respondent;           
               3.   whether SCC is entitled to expenses for construction              
          costs and general and administrative expenses related to its                
          homebuilding business during the years at issue in excess of                
          those allowed by respondent.  We hold SCC is entitled to deduct             
          certain expenses as redetermined herein;                                    
               4.   whether Mr. Strong had additional income for the years            
          at issue for constructive dividends from SCC, deposits of SCC’s             
          funds for his personal use, and the corporation’s payment of his            
          personal expenses.  We hold he did as redetermined herein;                  
               5.   whether Mr. Strong is liable for the fraud penalty                
          under section 6663 on his underpayment of tax for each of the               
          years at issue.  We hold he is;                                             
               6.   whether SCC is liable for the addition to tax under               
          section 6651(f) for fraudulent failure to file timely on its                
          underpayment of tax for each of the years at issue.  We hold that           
          SCC is not liable for the section 6651(f) addition to tax; and              
               7.   alternatively, whether SCC is liable for the addition             
          to tax under section 6651(a)(1) for failure to file timely tax              
          returns.  We hold that SCC is liable for the section 6651(a)(1)             
          addition to tax.                                                            









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