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1996, Canyon State Chiropractic was operated as a sole
proprietorship. Canyon State Chiropractic LLC was created on or
about August 14, 1996. Canyon State Chiropractic LLC had three
named members: Storks, petitioner, and Taurus Enterprises.
Storks and petitioner continued to control the business
operations of Canyon State Chiropractic after the creation of the
LLC.
The proposed stipulation stated that petitioner filed a
joint Form 1040, U.S. Individual Income Tax Return, with Storks
for 1996 but did not file an income tax return for 1997. A copy
of a Form 1065, U.S. Partnership Return of Income, filed by
Canyon State Chiropractic LLC for 1996 and a Notice of Final
Partnership Administrative Adjustment (FPAA) sent to the
partnership for 1996 were attached to the proposed stipulation.
The proposed stipulation also stated that there was no petition
filed with the Tax Court in response to the FPAA, Canyon State
Chiropractic LLC did not file a return for 1997, and Taurus
Enterprises did not file any tax returns for 1996 or 1997.
Finally, copies of various records of the bank accounts that were
used by respondent in determining petitioner’s gross receipts for
1996 and 1997 were attached to the proposed stipulation. Among
the records were bank statements, addressed to Canyon State
Chiropractic Clinic, petitioner, and Storks, and signature cards
for two of the three bank accounts. One of the signature cards
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Last modified: May 25, 2011