V.R. DeAngelis M.D.P.C. & R.T. Domingo M.D.P.C., V. R. DeAngelis M.D.P.C., Tax Matters Partner, et al. - Page 4




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          income received by each doctor from his S corporation.  Second,             
          respondent determined that each doctor received income under                
          section 61(a) in the amount of the life insurance premiums that             
          were paid by his S corporation on his behalf.                               
               We decide whether the S corporations and VRD/RTD were                  
          entitled to deduct the payments related to the STEP plan as                 
          ordinary and necessary business expenses under section 162(a).              
          We hold they were not to the extent that the payments related to            
          the life insurance written on a life of someone other than Ms.              
          Quinn.3  We also decide whether each doctor realized income in              
          the amount of the life insurance premiums that were paid by his S           
          corporation on his behalf.  We hold he did not.                             
                                  FINDINGS OF FACT                                    
          I.  Preliminaries                                                           
               Some facts were stipulated.  The stipulated facts and the              
          exhibits submitted therewith are incorporated herein by this                
          reference.  We find the stipulated facts accordingly.  VRD/RTD              
          had a legal address in the State of New York when its petition              
          was filed.  The individual petitioners resided in the State of              
          New York when their petitions were filed.                                   




               3 We understand respondent to have conceded that the                   
          payments are deductible to the extent they relate to the                    
          insurance written on the life of Ms. Quinn.                                 






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