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Petitioner timely petitioned this Court for redetermination
based on respondent’s notice of deficiency. Respondent filed an
answer with this Court.
Petitioner submitted a qualified settlement offer to
respondent in which petitioner offered to settle the case for an
increase in petitioner’s income tax liability for 1999 in the
amount of $100 and for an increase in petitioner’s income tax
liability for 2000 in the amount of $117. Respondent did not
accept this qualified offer.
The issues for decision in Morrison were: (1) Whether
payments made on behalf of petitioner or disbursements directly
to petitioner by Caspian Consulting Group, Inc.3 (Caspian),
during 1999 and personal charges petitioner made on a company
credit card in 2000 were constructive dividends; and (2) whether
petitioner was liable for an accuracy-related penalty under
section 6662(a) for 1999.
On March 23, 2005, this Court filed a memorandum opinion
finding for petitioner, that the 1999 payments and disbursements
and the 2000 personal charges were loans and not constructive
dividends. Therefore, there were no deficiencies in tax for
petitioner for the years 1999 and 2000 except for the item
3 Petitioner owned 40 percent of the outstanding stock of
Caspian Consulting Group, Inc., a C corporation.
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