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 9

                                         -9-                                          
          reported that DDL had paid wages to petitioner in his capacity as           
          DDL’s employee.                                                             
          E.  1990 and 1991 Tax Returns                                               
               The Les filed joint 1990 and 1991 Federal individual income            
          tax returns.  These returns were signed by both of the Les.  The            
          Les reported on these returns that they had realized gross income           
          in amounts which did not include the amount of any of the                   
          attorney checks.                                                            
               Petitioner filed on behalf of DDL 1990 and 1991 Federal                
          corporate income tax returns.  Those returns, which petitioner              
          signed in his capacity as an officer of DDL, reported that DDL              
          was incorporated on January 3, 1983,7 and that DDL owned as of              
          the end of each respective year a significant dollar amount of              
          assets.8  The corporate returns also reported for each respective           
          year that DDL had realized a significant dollar amount of gross             
          receipts and had paid a significant dollar amount of varied                 
          expenses, including an expense for petitioner’s officer                     
          compensation.                                                               



               7 Whereas petitioner actually incorporated his medical                 
          practice on Dec. 22, 1982, we consider DDL’s tax returns to state           
          erroneously that it was incorporated on Jan 3, 1983.                        
               8 The respective returns report that DDL’s assets and                  
          liabilities at the end of 1990 were $23,358 and $6,918,                     
          respectively, and at the end of 1991 were $23,891 and $3,588,               
          respectively.  The respective returns also reported that DDL had            
          retained earnings of $3,940 and $7,803.                                     





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