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Forms 1120 for the audit years (other than compensation of
officers).
b. Collections
The record does not contain reliable records of collections
for 1994. At trial, respondent argued that, because Dr. Snyder’s
billings for 1994 “were paid, to an extremely large percent, by
Blue Cross-Blue Shield or Medicare” it was appropriate to treat
his collections as equal to his net billings for the year:
$245,597. Exhibit 8-J, prepared by petitioner’s accountant,
alleges Dr. Snyder’s 1994 collections to be $146,837. Neither of
those conclusions is supported by the evidence, which consists
mainly of Dr. Mann’s testimony that petitioner’s collections are
“probably between 60 to 70 percent of * * * net billings”.
Because petitioner has not presented any evidence to the
contrary, we shall assume that Dr. Snyder’s collections for 1994
were at the high end of petitioner’s estimated range, i.e.,
70 percent of net billings, or $171,918. The parties have
stipulated that collections attributable to Dr. Vaughan for 1995
were $125,467. We also find, based upon an attachment to
petitioner’s expert report, that collections attributable to
Dr. Snyder for 1995 (to which no expenses are allocable because
Dr. Snyder was not an employee during 1995) were $4,338.96.
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