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Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
I. FINDINGS OF FACT
Some of the facts have been stipulated and are so found.1
A. Petitioner
1. Incorporation of Richard A. Cole, M.D., Inc.
Richard A. Cole (Dr. Cole) received his undergraduate degree
from Tufts University and his medical degree from Johns Hopkins
Medical School. During the years in issue, Dr. Cole was a
practicing physician who specialized in endocrinology.
Richard A. Cole, M.D., Inc. (petitioner), is a Pennsylvania
corporation incorporated by Dr. Cole on June 1, 1979. Dr. Cole
was petitioner's president and sole shareholder in fiscal years
1987 and 1988. Petitioner was in the business of providing
medical services during fiscal years 1987 and 1988.
2. Petitioner's Bank Accounts
During the tax years at issue, petitioner maintained
accounts at Marine Bank, Northwest Mutual Savings Bank, and
Mellon Bank. Petitioner received interest income of $1,333 in
fiscal year 1987 and $5,189 in fiscal year 1988 on its Marine
Savings Bank savings account.
1 The stipulated facts were deemed established for purposes
of this case. See par. I-E, below.
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