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Year Deficiency 6651(a)(1) 6654
1992 $43,505 $10,376 $1,011
1993 45,097 11,274 ---
We must decide whether to sustain these determinations. We
hold in respondent's favor. Section references are to the
Internal Revenue Code in effect for the subject years. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated. These stipulations
and the exhibits submitted therewith are incorporated herein by
this reference. Petitioner resided in Charlotte, Michigan, when
he petitioned the Court.
Petitioner did not file a Federal income tax return for
either of the subject years. During those years, petitioner was
a licensed dentist, and he operated a dental practice as a sole
proprietor. During 1992, petitioner received the following
amounts of money for his dental services:
Payer Amount
Delta Dental Plan of Michigan $79,682
The Travelers 4,854
Aetna Life Insurance Co. 6,488
Metropolitan Life Insurance Co. 5,634
SET, Inc. 1,664
Blue Cross Blue Shield of Michigan 5,537
Prudential Insurance Co. of America 1,960
Phoenix Home Life Mutual 655
Delta Dental Plan of California 2,638
Alexis, Inc. 1,957
Spartan Motors 6,592
Oxyfresh USA, Inc. 798
Connecticut General Life Insurance Co. 2,104
Continental Assurance Co. 624
John V. Carr & Son 640
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Last modified: May 25, 2011