Robinson v. Comm'r
United States Tax Court
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.
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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 P derives from C's transactions, P contends that C's period for assessment should govern R's ability to make a determination and/or assess tax with respect to P or C. Sec. 6501(a), I.R.C., provides the general rule…
1Opinion of the Court
OLIVER K. ROBINSON AND DEBORAH L. ROBINSON, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Robinson v. Comm'r
No. 4428-98; No. 4429-98; No. 4435-98
United States Tax Court
117 T.C. 308; 2001 U.S. Tax Ct. LEXIS 56; 117 T.C. No. 25;
December 19, 2001, Filed
Respondent was not time barred from determining constructive dividends for petitioners' 1992 tax year; respondent is sustained on adjustment with respect to disputed constructive dividends. Petitioners were employees of corporation and not subject to self- employment tax for their 1992 and 1993 tax years. Petitioners failed…
2Cases cited29 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Adler v. CommissionerUnited States Tax Court · 1985
- Simpson v. CommissionerUnited States Tax Court · 1975
- Bufferd v. CommissionerSupreme Court of the United States · 1993
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