- 28 - respondent’s proposed deduction disallowance, for both 1994 and 1995, is limited to collections attributable to the nonshareholder surgeons less applicable direct costs and allocable overhead. On both occasions, the Court suggested that it would be helpful if the parties were able to stipulate as to the proper allocation of overhead attributable to collections generated by Drs. Snyder and Vaughan. To that end the Court agreed to leave the record open for 30 days for such stipulations by the parties. The parties failed to stipulate agreed allocations of overhead. It is therefore left to the Court to make the required overhead allocations, on the basis of the evidence in the record. In his proposed findings of fact, respondent attempts to compute the portion of petitioner’s total expenses attributable to Dr. Snyder for 1994 and to Dr. Vaughan for 1995. Respondent subtracts those allocated expenses, for 1994, from Dr. Snyder’s deemed collections (considered by respondent to equal his net billings for that year) and, for 1995, from actual collections attributed to both Dr. Snyder and Dr. Vaughan, in order to derive the deemed dividend for each year. Petitioner objects to respondent’s computation of Dr. Snyder’s collections for 1994 and to respondent’s allocations of expenses for both years. The expenses subject to allocation are those deducted on petitioner’sPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011