David D. Le, a.k.a. David Dung Le, a.k.a. Dung V. Le and Kim Huong Le, a.k.a. Kim Le, et al. - Page 1


                                 T.C. Memo. 2003-219                                  

                               UNITED STATES TAX COURT                                

              DAVID D. LE, a.k.a. DAVID DUNG LE, a.k.a. DUNG V. LE &                  
                KIM HUONG LE, a.k.a. KIM LE, ET AL.,1 Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 13703-99, 10851-01,      Filed July 22, 2003.              

                    P-H is a physician in California who during 1990                  
               and 1991 performed his medical services through a                      
               business known as David Dung Le, M.D., Inc. (DDL).  R                  
               determined for those years that (1) DDL was a                          
               corporation that realized unreported income from third                 
               party payments made to it but diverted to the use of                   
               P-H and P-W (collectively, Ps) and (2) Ps received                     
               unreported constructive distributions on account of the                
               diversions.  R determined as to the payments that Ps                   
               owed 1990 and 1991 Federal individual income taxes and                 

               1 Cases of the following petitioners are consolidated                  
          herewith:  David D. Le, a.k.a. David Dung Le, a.k.a. David Le,              
          a.k.a. Dung V. Le, a.k.a. Dung Le, Transferee, docket No.                   
          10851-01; Kim Huong Le, a.k.a. Kim H. Le, a.k.a. Kim Le, a.k.a.             
          Nguy Le, Transferee, docket No. 10852-01.                                   

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