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II. Individual Petitioners
A. Overview
Petitioner doctors are Vincent DeAngelis (Dr. DeAngelis),
Rodolfo Domingo (Dr. Domingo), Keith Durante (Dr. Durante), and
Anthony J. Capizzi (Dr. Capizzi) (collectively, doctors). During
1993 and 1994, each doctor wholly owned an S corporation that
employed the doctor to provide his medical and surgical services
for VRD/RTD. Each S corporation was a professional corporation
(PC), the sole employee of which was its owner. The names of the
PCs of Drs. DeAngelis, Domingo, Durante, and Capizzi were Vincent
R. DeAngelis M.D.P.C., Rodolfo T. Domingo M.D.P.C., Keith Durante
M.D.P.C., and Anthony J. Capizzi M.D.P.C., respectively.
Each doctor and his wife filed a joint Form 1040, U.S.
Individual Income Tax Return, for each of the years 1993 and
1994. Each couple’s returns reported compensation received from
the doctor’s PC during those years.4
4 We use the term “compensation” to refer to wages,
salaries, and the like. Unlike petitioners, we do not consider
the term “compensation” to include the doctors’ distributive
shares of income from their PCs. See sec. 61(a)(1), (13)
(distinguishing as separate items of gross income "Compensation
for services, including fees, commissions, fringe benefits, and
similar items" from "Distributive share of partnership gross
income"); cf. Campbell v. Commissioner, 943 F.2d 815, 822 (8th
Cir. 1991), affg. in part and revg. in part on other grounds T.C.
Memo. 1990-162. Nor (as discussed below) does the STEP plan
define the term “compensation” to include such distributive
shares.
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