K & M La Botica Pharmacy, Incorporated, et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               SWIFT, Judge:  Respondent determined deficiencies in and               
          additions to petitioners’ respective individual and corporate               
          Federal income tax liabilities, as follows:                                 

          Khaled Ahmed, Docket Nos. 17346-99 and 17725-99                             
                              Sec.          Sec.      Sec.     Sec.                   
          Year   Deficiency    6651(a)(1)    6651(f)     6654     6663(a)             
          1995   $   25,790   $  4,628       -        -     $   19,343                
          1996      299,639        -         -        -        224,729                
          1997    1,382,352   345,236         -        -      1,036,764               
          1998    3,121,466         -      $2,341,100  $141,678       -               
          K & M La Botica Pharmacy, Inc., Docket Nos. 8134-00 and 10500-99            
          1995      114,643   -            -        -         85,982                  
          1996       80,552       22,647         -        -         60,414            

               Based on petitioner Khaled Ahmed’s (Ahmed) and his wife’s              
          joint Federal income tax returns for 1995, 1996, and 1997 that              
          were filed with respondent, respondent’s notices of deficiency              
          for those years were issued to both Ahmed and to his wife.  Ahmed           
          and his wife’s joint Federal income tax return for 1998 was not             
          filed until after respondent had prepared a substitute tax return           
          and had issued a notice of deficiency for 1998 to Ahmed                     
          individually.                                                               
               All of respondent’s income and expense adjustments reflected           
          in the above notices of deficiency relate just to Ahmed’s                   
          separate business activities, and respondent’s determinations of            
          fraud do not relate to Ahmed’s wife.  Ahmed’s wife did not join             
          Ahmed in filing the instant petition.                                       






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