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petition to this Court was filed. She was almost 60 years of age
at the time of her trial.
Petitioner is single, and she filed as such on each of her
Federal income tax returns for 1988 through 2002. She has an
individual retirement account (IRA) for which she deducted
contributions of $2,000 for each of the years from 1988 through
1992. The record does not disclose whether she made any other
contributions to the IRA.
II. Petitioner’s Dental Practice
Petitioner is a dentist. She graduated from dental school
in 1981, and she has practiced dentistry ever since. She started
her own dental practice in 1983, and she has continued to date to
work in or for that practice.
In or about 1987, petitioner incorporated her dental
practice as Elizabeth Giles, D.D.S., Inc. (Giles Inc.). She is
the sole shareholder of Giles Inc., and she is one of its
employees. From 1988 through 2002, she worked 4 days a week as a
dentist for Giles Inc., for a total of 36 hours per week, and she
received wages from Giles Inc. in the following amounts:
Year Wages
1988 $110,863
1989 108,000
1990 126,194
1991 111,515
1992 108,287
1993 108,456
1994 114,611
1995 109,086
1996 105,453
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