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3. whether they are liable for additions to tax pursuant
to sections 6651, 6653, and 6661 for their 1987 taxable year.
B. Issues With Respect to Petitioner Douglas R. Prince, D.D.S.,
M.S., P.C.
1. Whether certain payments made by petitioner Douglas R.
Prince, D.D.S., M.S., P.C. to petitioner Douglas R. Prince are
deductible as compensation expenses pursuant to section 162; and
2. whether petitioner Douglas R. Prince D.D.S., M.S., P.C.
is liable for additions to tax pursuant to sections 6651, 6653,
and 6661.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations of facts are incorporated
herein by reference and are found as facts in the instant case.
During the relevant taxable years, petitioner Douglas R.
Prince (hereinafter individually referred to as petitioner) owned
all of the stock of petitioner Douglas R. Prince, D.D.S., M.S.,
P.C., a professional corporation (hereinafter referred to as the
corporation) that was organized pursuant to the laws of the State
of North Dakota.
At the time the petition in docket No. 22467-93 was filed,
petitioners Douglas R. Prince and Jane E. Prince (hereinafter
jointly referred to as petitioners) resided in DuPage County,
Illinois. At the time the petition in docket No. 8457-94 was
filed, the corporation's principal office was at 358 East First
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