- 10 -
1993
10/1991 12/1991 1992 (As amended)
Total income $2,303,425 $403,869 $2,411,265 $2,286,460
Officers’ compensation 987,554 350,000 1,171,931 940,895
Salaries & wages 148,750 29,167 200,565 303,750
Pension, profit-sharing, plans 46,907 25,000 132,428 169,170
Employee benefit programs -0- -0- -0- -0-
Other deductions (VEBA contribution) 480,901 -0- 209,869 296,056
Taxable income (loss) 3,664 (103,857) (23,325) (7,796)
Income tax 1,246 -0- -0- -0-
Alt. minimum tax -0- -0- -0- 20,531
It filed its 1992 Federal corporate income tax return untimely on
May 28, 1993.
Marlton is a sole proprietorship owned by Wan B. Lo (Dr.
Lo), and he reports Marlton’s income and expenses on his personal
Schedule C, Profit or Loss from Sole-Proprietor Business, using
the cash receipts and disbursements method and the calendar year.
Dr. Lo reported the following amounts for Marlton on Schedules C
of his joint 1993 and 1994 Federal individual income tax returns:
1993 1994
Gross income $875,477 $868,275
Wages 130,944 124,939
Pension, profit-sharing, plans 16,920 17,396
Employee benefit programs 100,000 120,000
Net profit 406,863 381,122
Dr. Lo and his wife, Cecilia (Ms. Lo) (collectively, the Los),
resided in New Jersey when we filed their petition.
II. The Subject VEBA’s
Pacific Executive Services (PES) was a California
partnership formed by two insurancemen named Stephen R. Ross (Mr.
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