- 7 - have hospital privileges, in Tarrant County, Texas, he must pay petitioner $5,000 a month until 96 months have passed. Cash Bonuses In the middle of each month, petitioner would determine the amount remaining in its bank account and the amount of cash necessary to meet anticipated cash-flow needs for the immediate and near future. The balance in the account, if any, was paid out, in equal amounts, as bonuses to the shareholder surgeons, pursuant to the shareholder employment agreements. Audit Year Compensation of Shareholder Surgeons On petitioner’s U.S. Corporation Income Tax Returns, Forms 1120 (Forms 1120), for the audit years, petitioner deducted compensation paid to shareholder surgeons under the heading “Compensation of officers”, in the following amounts: 1994 1995 Dr. Ellis $239,866 $172,896 Dr. Mann 347,968 452,969 Dr. Miller 355,391 450,485 Dr. Black 357,006 451,775 Total 1,300,231 1,528,125 All such payments were subjected to appropriate wage withholding and were reported on Forms W-2, Wage and Tax Statements, issued by petitioner to the shareholder surgeons. Nature of Petitioner’s Income From Shareholder Surgeons All of the income received by petitioner on account of the employment of the shareholder surgeons was received on account of the provision of medical services by those shareholder surgeons.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011