Oliver K. Robinson and Deborah L. Robinson v. Commissioner

117 T.C. No. 25

UNITED STATES TAX COURT OLIVER K. ROBINSON AND DEBORAH L. ROBINSON, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4428-98, 4429-98, Filed December 19, 2001. 4435-98. R determined that certain expenditures made by P’s wholly owned subch. C corporation (C) constituted constructive dividends to P. At the time that R mailed a notice of deficiency to P, the period for assessment of 1992 fiscal year tax with respect to C had expired, whereas the period for assessment of 1992 tax for P had been extended and had not expired. Because the adjustment to…