Richard A. Cole, M.D. Inc. - Page 3

                                        - 3 -                                         

               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.                                         

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011