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submitted to respondent a letter from the vice president for
finance at NYU Medical Center dated March 9, 1998, and reading as
follows:
To: Internal Revenue Service
Alec Megibow, MD, Social Security No. * * * , is a full
time faculty member and employee of the New York
University School of Medicine. Dr. Megibow serves as a
participating physician in a unit of physicians which
provides professional radiologic services for patients.
Billings to patients for services rendered by
Dr. Megibow are made to his name. Under the terms of
an agreement entered into between this institution and
the participating physicians in the unit, all income
derived from these professional services is remitted to
New York University Medical Center and is credited to a
special fund.
Funds disbursed to the participating physician are
reflected in their respective W-2 forms issued by New
York University Medical Center.
During the calendar year 1997, $506,503.15 was
collected for billings rendered in Dr. Megibow’s name.
Such amount was duly remitted to the Medical Center and
credited to the aforementioned special fund. No part
of such receipts was retained by Dr. Megibow.
On March 17, 2000, Ms. O’Connell mailed to Mr. Gendler a
second Form 4564 with respect to 1997. This Form 4564 asked for
certain items outstanding from the October 5, 1999 request,2 for
example: “Another letter from NYU is needed outlining the
reimbursment [sic] policy of expenses incurred by the doctor and
2 This Form 4564, Information Document Request, identified
in the top right-hand corner as “Request Number 2”, by apparent
typographical error referred to the earlier Form 4564 as “IDR #2
issued on 10/05/99”. The Form 4564 issued on Oct. 5, 1999, is in
fact designated on its face as “Request Number 1” for 1997.
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