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Although Mr. Wilson was not a licensed pharmacist in the
State of Maryland during 1993 and 1994, he distributed through
Pleasantville during those years medication and medical supplies
to patients of Industrial Medical.
During 1993 and 1994, petitioners, as contractors for
Industrial Medical, received the following amounts of
compensation from that business in the form of checks written on
its business operating bank account:3
Mr. Wilson’s Compensation from Industrial Medical
Year Amount of Compensation
1993 $44,000
1994 30,621
Ms. Wilson’s Compensation from Industrial Medical
Year Amount of Compensation
1993 $7,315
1994 15,030
Industrial Medical accounted for the foregoing amounts of
compensation paid to Mr. Wilson and to Ms. Wilson as “Contract
Service Expenses”. In the corporate income tax return that
Industrial Medical filed for each of its taxable years 1993 and
1994, Industrial Medical deducted the respective amounts of
compensation that it had paid to Mr. Wilson and to Ms. Wilson
3Industrial Medical also paid compensation to other contrac-
tors in the form of checks written on its business operating bank
account.
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Last modified: May 25, 2011