-17-
Such is especially so, considering that the Les acknowledged
as part of their separate plea agreements that petitioner’s
medical practice was known during 1990 as “David Dung Le, M.D.,
Inc.”11, that DDL was active during that year, and that DDL
during that year received the same attorney checks that are at
issue herein in payment of medical services which were rendered
on behalf of it. In light of these plea agreements, we reject
petitioners’ attempt to disavow their acknowledgments as set
forth clearly in the agreements. We consider it unimportant that
the corporate and Federal employer identification numbers used on
the corporate returns and estimated payment vouchers were
initially assigned to a corporation named “Dung Van Le, A Medical
Corporation”. Similarly, we place no importance with respect to
petitioner’s corporation’s never having been registered with the
State of California to do business as DDL. In both cases,
petitioner called himself Dung Van Le when he incorporated his
medical practice as Dung Van Le, A Medical Corporation. During
the subject years, however, when he called himself David Dung Le,
he simply used a different name for his corporation to reflect
the change in his personal name. The fact that petitioner did
not notify the State of California that he had changed the name
of his medical practice to reflect his change in name does not
11 Ms. Le also acknowledged in her plea agreement that
petitioner’s medical practice was known as DDL in 1991.
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