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Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession by petitioners, we must decide the
following issues:
(1) Whether, during the years in issue, petitioner Harish K.
Pariani was an employee or an independent contractor of his
wholly owned professional association for Federal income tax
purposes. We hold that he was an employee.
(2) Whether petitioners are liable for the accuracy-related
penalties as determined by respondent. We hold that they are so
liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, first
supplemental stipulation of facts, and attached exhibits. At the
time of filing the petition, petitioners resided in Humble,
Texas.
The Professional Association
Petitioner Harish K. Pariani (Dr. Pariani) is a doctor of
medicine. In 1982, Dr. Pariani organized, under the laws of the
State of Texas, a professional association called Harish K.
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