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Petitioner is a practicing physician specializing in adult
and pediatric urology. He operates his own medical practice,
David L. Samuel, M.D., A Professional Medical Corporation.
Petitioner is also a partner in Pontchartrain Lithotripsy, LLC.
Prior to starting his own practice, petitioner practiced with
another urologist until sometime in 2002.
Beginning on February 3, 2003, petitioner began filing
delinquent individual income tax returns for 1996-2002. The
dates on which petitioner filed the returns and the Internal
Revenue Service (IRS) assessed the taxes due are as follows:
Year Date Return Filed Date Taxes Assessed
1996 January 26, 2004 March 8, 2004
1997 February 3, 2003 March 24, 2003
1998 February 3, 2003 March 31, 2003
1999 February 3, 2003 March 24, 2003
2000 February 3, 2003 March 3, 2003
2001 February 3, 2003 March 3, 2003
2002 October 3, 2003 November 3, 2003
The so-called “TXMODA” computer transcripts of petitioner’s IRS
accounts for each of these years show adjusted gross income
posted from petitioner’s tax returns as follows:
Year AGI
1996 $187,108
1997 220,250
1998 205,492
1999 303,558
2000 140,213
2001 177,566
2002 211,991
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Last modified: November 10, 2007