Paul Arthur Zipp - Page 6

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          account at First Interstate Bank (the refund account) to handle             
          the payments refunded to patients.  Petitioner would transfer               
          funds from the main account to the refund account and his friend            
          Julie Anne Stanbery (Ms. Stanbery) would then write a check from            
          the refund account to reimburse the patient for the overpayment.            
               By late 1989, petitioner agreed to pay the hospital up to              
          $1,500 per month for clerical and other services.  Petitioner               
          also paid other radiologists for professional services they                 
          rendered in the radiology department of the Highline Community              
          Hospital.  He treated the radiologists as independent contractors           
          and filed Forms 1099 with the Internal Revenue Service (IRS) to             
          report the payments he made to them.  For the taxable years 1990            
          and 1991, he deducted the payments made to other radiologists as            
          an outside services expense on the Schedules C attached to his              
          income tax returns.                                                         
               During the taxable years 1990 and 1991, petitioner wrote               
          checks to Ms. Stanbery totaling $49,685 and $45,700,                        
          respectively.  On the Schedules C attached to his income tax                
          returns for those years, petitioner deducted the amounts paid to            
          Ms. Stanbery as business expenses for outside services.                     
          Petitioner, however, did not file a Form W-2 or a Form 1099 for             
          the amount paid to Ms. Stanbery for either year.                            
               Petitioner did not employ a bookkeeper or use a bookkeeping            
          system.  Petitioner's accountant has prepared petitioner's tax              





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