-3-
or petitioners), and (2) the Les’ liability for the unpaid 1990
and 1991 Federal corporate income taxes (inclusive of penalties)
of a California corporation known as David Dung Le, M.D., Inc.
(DDL). Respondent determined deficiencies in the Les’ 1990 and
1991 Federal income taxes and fraud penalties under section
6663(a) and reflected those determinations in a notice of
deficiency issued to the Les on July 7, 1999.2 Respondent
determined that the Les, as transferees of DDL’s assets, are also
liable for DDL’s unpaid 1990 and 1991 Federal corporate income
tax liabilities (inclusive of penalties) and reflected this
determination in separate notices of determination of transferee
liability issued to petitioner and Ms. Le on June 5, 2001.3 As
determined by respondent, the amounts of the Les’ deficiencies
and fraud penalties and the amounts of DDL’s unpaid liabilities
are as follows:
2 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
3 On July 1, 1999, respondent had issued DDL a notice of
deficiency as to Federal corporate income taxes and fraud
penalties under sec. 6663(a). DDL, through its current counsel,
Wayne Hagendorf (Mr. Hagendorf), petitioned the Court with
respect thereto. Following our dismissal of that case for lack
of jurisdiction, see David Dung Le, M.D., Inc. v. Commissioner,
114 T.C. 268 (2000), affd. 22 Fed. Appx. 837 (9th Cir. 2001),
respondent, on July 31, 2000, assessed the deficiencies and
penalties listed in the notice of deficiency. These deficiencies
and penalties are the corporate liabilities at issue.
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