Rosalinda E. Alt - Page 7




                                         - 7 -                                          
          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.                    





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011