K & M La Botica Pharmacy, Incorporated, Et Al. - Page 3

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          and expenses to be charged to each petitioner for each year in              
          issue.                                                                      
               As a result of the above stipulations, the parties                     
          represented to the Court that the Court needed to decide only               
          whether petitioners for the years in issue were liable for civil            
          fraud.                                                                      
               Ahmed, however, in his pending Rule 155 computations and               
          related briefs makes several meritless arguments in an apparent             
          attempt to alter the parties’ stipulations.  For example, Ahmed             
          argues that he is entitled to additional deductions, that                   
          different amounts of income should be charged to Ahmed than the             
          amounts reflected in the parties’ stipulations, that in certain             
          years Ahmed should compute his individual income tax liability as           
          if he were a corporation, and that respondent should not be                 
          allowed to submit computations that differ from respondent’s                
          proof of claims filed previously with the Bankruptcy Court.                 




               2(...continued)                                                        
                    Hereinafter, we sometimes refer to the above                      
               entities formed by Ahmed as the “nominee entities” –-                  
               reflecting the fact that Ahmed, during at least 1997                   
               and 1998, personally and solely managed and                            
               controlled essentially all significant aspects of the                  
               operations and activities of the pharmacies, the                       
               medical clinics, and the medical laboratory; that                      
               Ahmed treated the nominee entities as his alter ego;                   
               and that for Federal income tax purposes for 1997 and                  
               1998 all income and expenses of the nominee entities                   
               are to be charged to Ahmed personally.                                 





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