HJ Builders, Inc. - Page 2

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          taxable year ended May 31, 2002, and with respect to petitioners            
          Paul W. and Charlene R. Wright (Mr. and Mrs. Wright,                        
          respectively; the Wrights, collectively) for their taxable year             
          ended December 31, 2001, as follows:                                        
                                        Penalty, I.R.C.                               
               Docket No.   Deficiency           Sec. 6662                            
               8841-05        $8,821         $1,764.20                                
               8842-05        55,562         11,112.40                                
               After concessions by both parties, the issues remaining for            
          decision are:                                                               
               (1) Whether disbursements of funds from HJ Builders to                 
          Mr. Wright are constructive dividends or repayments of loans;               
               (2) whether disbursements of funds by HJ Builders to and on            
          behalf of the Wrights’ church are deductible by HJ Builders as              
          charitable contributions of the corporation or should be                    
          characterized as constructive dividends to the Wrights,                     
          deductible as charitable contributions by the Wrights;                      
               (3) whether expenses paid by HJ Builders with regard to a              
          Lexus SUV used by Mrs. Wright are business expenses deductible by           
          HJ Builders or are constructive dividends to the Wrights; and               
               (4) whether HJ Builders or the Wrights are liable for                  
          accuracy-related penalties under section 6662.                              
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             







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Last modified: May 25, 2011