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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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