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received from Dr. Alt’s medical practice (William J. Alt, M.D.,
P.C.) as corporate distributions were taxable income. Respondent
made other adjustments, including additions to tax for fraud.
On January 10, 1992, petitioner and Dr. Alt filed a petition
with the Court to dispute the notices of deficiency for the 1982,
1983, 1984, 1986, 1987, and 1988 taxable years. On January 13,
1992, Dr. Alt filed a petition to dispute the notice of
deficiency for the 1989 taxable year. On February 22, 1993, the
parties filed a Stipulation of Settlement with this Court, in
which petitioner and Dr. Alt agreed that they were liable for the
following deficiencies and additions to tax4 for the 1982, 1983,
1984, 1986, 1987, and 1988 taxable years:5
Additions to Tax1
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b) 6661
1982 $78,510 $39,255 --- $19,628
1983 176,832 88,416 --- 44,208
1984 160,170 80,085 --- 40,043
1986 222,252 166,689 --- 55,563
1987 230,686 173,014 --- 57,671
1988 221,009 --- $165,756 55,252
1 Further additions to tax were applied to the
taxable years 1982, 1983, and 1984 under sec.
3(...continued)
deficiencies for the 1987 and 1988 taxable years.
4 Amounts are rounded to the nearest dollar amount.
5 Within the Stipulation of Settlement, Dr. Alt also agreed
that he was liable for a $479,404 deficiency and a $359,553
addition to tax under sec. 6663 for the 1989 taxable year.
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