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Steven J. Mopsick and Betty J. Williams, for petitioners.
Christian A. Speck and Kathryn K. Vetter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes for the 1994 taxable year as
follows:
Docket No. Petitioner1 Deficiency
10930-02 Derby $16,739
10931-02 Droubay 24,950
10932-02 Eusebio 14,237
10933-02 Harris 9,724
10934-02 Hirsch 8,008
10935-02 Smith-Hoefer 33,237
10936-02 Kennedy 13,917
10937-02 Levin 41,320
10939-02 Smith-MacLean 12,170
10941-02 Patterson 23,091
10942-02 Silva 26,976
10943-02 Women's Health Assocs. 2162,926
10945-02 Watts-White 13,341
1 Although petitioners filed joint returns, for
convenience we use the surnames of the spouses whose
medical practice transfers are at issue in these cases.
2 Adjustment to the charitable contribution deduction
claimed by the partnership. The resulting deficiencies
to the partners, Dr. Leon Schimmel and Dr. Carol Lynne
Conrad-Forrest, are not at issue in these cases.
In his answers, respondent affirmatively alleges that the
individual petitioners are liable for accuracy-related penalties
for gross valuation misstatements equal to 40 percent of the
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