- 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
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