- 3 -
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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Last modified: May 25, 2011