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6653(b)(2), and to the taxable years 1986 and 1987
under sec. 6653(b)(1)(B).
On April 27, 1993, the Court entered a decision pursuant to this
stipulation of settlement. In March 1994, on the basis of the
reversal of Dr. Alt’s criminal conviction,6 petitioner and Dr.
Alt filed a motion to vacate or revise this decision with the
Court. The Court denied the motion. Alt v. Commissioner, T.C.
Memo. 1994-313.
After serving 25 months in prison, Dr. Alt reestablished his
medical practice in 1995. After the IRS seized assets to pay
taxes owed by petitioner and Dr. Alt, petitioner began to work as
a receptionist at her daughter Nan’s and Dr. Alt’s offices,
Clinical Psychiatric Medicine and Clinical Cardiology-Internal
Medicine, respectively. Petitioner is a corporate officer of
Clinical Cardiology-Internal Medicine, P.C. Petitioner and Dr.
Alt earned the following amounts from Dr. Alt’s medical practice
and petitioner’s receptionist work:
6 In 1990, Karen and Dr. Alt were indicted on five counts
of Federal tax violations under sec. 7201, including attempted
evasion, and aiding and abetting in the attempted evasion, of
personal and corporate income taxes of Dr. Alt for the taxable
years of 1983 and 1984. Karen and Dr. Alt were both convicted
and sentenced to imprisonment and fined. In June 1993, the U.S.
Court of Appeals for the Sixth Circuit reversed the convictions
due to an improper jury instruction. In May 1994, Dr. Alt
entered into a plea agreement and pleaded guilty to a misdemeanor
under sec. 7203 in exchange for the dismissal of the indictment
and commutation of the sentence to time already served.
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