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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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