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.
10852-01.
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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