T.C. Memo. 1997-464
UNITED STATES TAX COURT
ALPHA MEDICAL, INC., f.k.a. ALPHA MEDICAL MANAGEMENT, INC.,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22802-94. Filed October 14, 1997.
John P. Konvalinka and Thomas E. Smith, for petitioner.
Bonnie L. Cameron, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined a deficiency in
petitioner's 1990 Federal income tax of $1,376,520, and a penalty
under section 66621 of $275,304.
1 All section references are to the Internal Revenue Code
as in effect during the year in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated. All dollar amounts are rounded to the
nearest dollar unless otherwise indicated.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011