Rosalinda E. Alt - Page 8




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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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