Law Offices--Richard Ashare, P.C. - Page 1
















                                 T.C. Memo. 1999-282                                  


                               UNITED STATES TAX COURT                                


                  LAW OFFICES--RICHARD ASHARE, P.C., Petitioner v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18439-97.                  Filed August 24, 1999.           

                    P is a corporate law firm, and A is its sole                      
               shareholder and only professional employee.  P has                     
               represented a class of plaintiffs from 1974 to date and                
               was awarded $12,567,623 in legal fees when the case was                
               settled in 1989.  P received those fees from 1989                      
               through 1992 and is not entitled to further fees for                   
               significant ongoing services which it must perform on                  
               that case.  P's workload in and after 1990 was minimal,                
               except for the ongoing services.  P paid A $10,492,500                 
               of "compensation" from 1989 through 1992 and, for each                 
               year but one, reported no taxable income.  For 1990 P                  
               reported taxable income of $3,775,699; $2,487,547 was                  
               retained for P's future operations, and $1,282,998 was                 
               retained to pay P's 1990 Federal income tax liability.                 
               P paid A $1,750,000 of "compensation" during 1993 and                  
               reported a $1,857,933 loss that it carried back to 1990                
               to claim a refund of $581,812.  P borrowed $916,756                    
               from A and sold most of its assets to have the funds to                
               pay A the $1,750,000.  Exclusive of $1,373,913 of                      
               Federal income tax refunds received or accrued by P on                 






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