Pacella v. Commissioner
United States Tax Court
Prior to 1971, P operated two separate sole proprietorships: a private psychiatric hospital and a clinical psychiatric practice. In 1971, P incorporated his clinical psychiatric practice and entered into an exclusive employment contract with the corporation regarding his clinical psychiatric services. The corporation also adopted a qualified pension plan and medical reimbursement plan covering P. After January 1971, P's corporation billed private patients for P's services.
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Prior to 1971, P operated two separate sole proprietorships: a private psychiatric hospital and a clinical psychiatric practice. In 1971, P incorporated his clinical psychiatric practice and entered into an exclusive employment contract with the corporation regarding his clinical psychiatric services. The corporation also adopted a qualified pension plan and medical reimbursement plan covering P. After January 1971, P's corporation billed private patients for P's services. It also billed P's private psychiatric hospital for clinical psychiatric services rendered by P to inpatients at the…
1Opinion of the Court
Nims, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for the years 1971, 1972, and 1973, in the amounts of $17,980.80, $7,362.38, and $8,960.67, respectively. As a result of various concessions, the sole issue for decision is whether income attributable to petitioner Bernard L. Pacella’s medical practice is taxable to him instead of his wholly owned professional corporation.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation and the exhibits attached thereto are so found and incorporated herein by reference.
At the time the petition in this…
2Cases cited16 opinions
- Frye v. United StatesCourt of Appeals for the D.C. Circuit · 1923
- Achiro v. CommissionerUnited States Tax Court · 1981
- United States v. Roland Addison, United States of America v. Albert Henry RaymondCourt of Appeals for the D.C. Circuit · 1974
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Rubin v. CommissionerUnited States Tax Court · 1971
11 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Haag v. CommissionerUnited States Tax Court · 1987
- Johnson v. CommissionerUnited States Tax Court · 1982
- Bagley v. CommissionerUnited States Tax Court · 1985
- Leavell v. CommissionerUnited States Tax Court · 1995
33 more not listed; retrieve them via the Exa API.