Maurice C. Wilson and Dorris E. Wilson - Page 2




                                        - 2 -                                         
          and Mr. Wilson filed a reply (Mr. Wilson’s reply) to respondent’s           
          reply.1  We shall grant respondent’s motion.                                
                                     Background                                       
               All of the facts on which respondent relies in respondent’s            
          motion have been deemed established pursuant to the Court’s Order           
          under Rule 91(f)2 dated September 24, 2001, and pursuant to Rule            
          90(c).                                                                      
               At the time the petition in this case was filed, Mr. Wilson            
          resided in Goldsboro, North Carolina, and Ms. Wilson resided in             
          Myrtle Beach, South Carolina.                                               
               During 1993 and 1994, Mr. Wilson operated Pleasantville                
          Medical Services (Pleasantville) as a pharmacy.  Pleasantville              
          was located in Baltimore, Maryland, within the operating location           
          of DK Medical Services, Inc., d/b/a Industrial Medical and                  
          Physical Therapy (Industrial Medical).  Deborah Kolodner, Mr.               
          Wilson’s daughter, owned and operated Industrial Medical.                   


               1Petitioner Dorris E. Wilson (Ms. Wilson) did not sign Mr.             
          Wilson’s response, Mr. Wilson’s supplement to that response, or             
          Mr. Wilson’s reply.  There is no indication in the record that              
          Ms. Wilson authorized Mr. Wilson to speak on her behalf in those            
          filings.  We conclude that Ms. Wilson does not dispute that                 
          respondent’s motion should be granted as to her.  Assuming                  
          arguendo that we had not concluded that Ms. Wilson does not                 
          dispute that respondent’s motion should be granted as to her, on            
          the record before us, we conclude that respondent’s motion should           
          be granted as to Ms. Wilson.                                                
               2All Rule references are to the Tax Court Rules of Practice            
          and Procedure.  Unless otherwise indicated, all section refer-              
          ences are to the Internal Revenue Code in effect for the years at           
          issue.                                                                      




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011