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WELLE v. COMMISSIONER

Docket No. 156-11.

140 T.C. 420 (2013)

140 T.C. No. 19

TERRY J. WELLE AND CHRISSE J. WELLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 27, 2013.

Attorney(s) appearing for the Case

Jon J. Jensen , for petitioners.

Christina L. Cook , for respondent.

MARVEL, Judge:

Respondent determined a deficiency of $10,620 in petitioners' Federal income tax and an accuracy-related penalty under section 6662(a)1 of $2,124 for 2006. The issues for decision are: (1) whether petitioner Terry J. Welle received a constructive dividend of $48,275 from his wholly owned subchapter C corporation, Terry Welle Construction, Inc. (TWC), in 2006; and (2) whether petitioners are liable for the accuracy...

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