Mohan Roy, M.D., Inc. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               JACOBS, Judge: Respondent determined the following                     
          deficiencies, additions, and penalties with respect to petitioners'         
          Federal income taxes:                                                       
          Mohan Roy, M.D., Inc., Docket No. 6966-96:                                  
                    Additions to Tax & Penalties                                      
                    Sec.     Sec.                                                     
                    Year  Deficiency         6651(a)(1)  6662                         
                    1991   $20,613              ---     $4,123                        
                    1992     9,060             $3,967     ---                         
                    1993     8,933              ---      1,787                        
                    1994    14,535              ---      2,907                        
          Mohan and Vimal Roy, Docket No. 8728-96:                                    
                       Penalties                                                      
                                            Sec.                                     
                    Year      Deficiency     6662                                     
                    1991      $137,927      $27,585                                   
                    1992        62,449       12,490                                   
                    1993      218,464       43,693                                    
                    1994        48,036        9,607                                   
               These consolidated cases involve two physicians, Mohan and             
          Vimal Roy (hereinafter sometimes referred to as the Roys or as the          
          individual petitioners), and their professional corporation, Mohan          
          Roy, M.D., Inc. (hereinafter referred to either as Roy, Inc. or the         
          corporate petitioner).  During the years in issue, Roy, Inc. owned          
          or leased two luxury automobiles, a 1990  Silver Spur II Rolls              
          Royce and a Mercedes Benz S-500.                                            
               After concessions by respondent and petitioners, the primary           
          issue that remains concerns the Rolls Royce  automobile.                    




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