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petitioner. Dr. Kay was initially to be paid a certain amount
per working day and then, after 270 days, Dr. Kay's pay was to be
a 20-percent share of the net profits. On or about February 1,
1991, Dr. Kay presented a cashier's check in the amount of
$23,000 to petitioner's mother. On February 8, 1991, Dr. Kay
presented a check in the amount of $15,000 to petitioner's
mother. The February 8, 1991, check bore the notation "Deposit
for purchase of practice World Dental". On or about February 22,
1991, Dr. Kay presented a cashier's check in the amount of
$25,000 to petitioner's mother.
In late February 1991, petitioner received a check in the
amount of $33,000 from the account of World Medical/Dental. On
March 6, 1991, petitioner received an additional $25,000 from his
parents. These amounts were in addition to gifts that petitioner
received from his parents during 1991.
Pennsylvania Property
In February 1990, petitioner inherited property in
Pittsburgh, Pennsylvania (the Pennsylvania property). During
1990 and 1991, petitioner received no rental income from the
property. On his 1991 Schedule E, petitioner claimed rental
expenses totaling $3,955.42 relating to the Pennsylvania
property.
Dependency and Head of Household Status
Petitioner's mother and father did not file 1991 Federal
income tax returns. During 1991, petitioner's parents resided,
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