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Basile Health Center, DC, PC
Addition to tax Accuracy-related
delinquency penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1997 $55,971 $13,994 $11,194
Petitioners filed separate petitions to redetermine the
deficiencies and related penalties. We consolidated these cases
(hereinafter this case) for trial, briefing, and opinion,
pursuant to Rule 141(a), because they present common issues of
fact and law.
Background
Paul and Barbara Basile (the Basiles) are licensed
chiropractors. Basile Health Center, DC, PC (BHC), is one of
several business entities the Basiles have used to conduct their
chiropractic practice.
On January 10, 2002, respondent issued a notice of
deficiency to the Basiles in which he determined that certain
entities the Basiles used in running their chiropractic practice
were shams, and that the Basiles had used those entities to
underreport their income. Respondent also determined that the
Basiles had not established that they qualified for the disabled
access credit, that certain computational adjustments were
necessary, and that the Basiles were liable for deficiencies in
their income taxes, penalties, and an addition to tax.
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