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compensation of officers. In addition, the Association paid
$178,857 to Dr. Pariani for medical professional services
performed by him and deducted this amount under the heading
"other deductions". Petitioners reported wages of $19,631, which
included the $8,000 paid by the Association and $11,631 of Mrs.
Pariani's wages. Petitioners reported $178,857 as income from a
sole proprietorship.1 The Association paid $40,090 to persons
other than Dr. Pariani for medical professional services and
deducted this amount under the heading "other deductions".
Information Returns
For the 1989 tax year, no Forms W-2 or Forms 1099 were
issued to Dr. Pariani by the Association or by any other person.
For the 1992 tax year, the Association issued a Form W-2 to Dr.
Pariani showing $8,000 paid as compensation of officers. No
other Forms W-2, and no Forms 1099, were issued to Dr. Pariani by
the Association or by any other person for 1992. However, the
Association issued Forms 1099 to 13 other individuals, at least
one of whom was a doctor, for 1992.
OPINION
Evidentiary Matters
Petitioners did not appear or testify at the trial of this
case and called only one witness, Asit Modak, who was the
1 The Association did not include the payment of $178,857 in
its reportable wages on any Form 941, Employer's Quarterly
Federal Tax Return, filed for 1992.
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