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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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