-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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