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PACELLA v. COMMISSIONER

Docket No. 11372-77.

78 T.C. 604 (1982)

BERNARD L. PACELLA AND THERESA PACELLA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 14, 1982.

Attorney(s) appearing for the Case

Ephraim London, for the petitioners.

Theodore J. Kletnick and Anne Hintermeister, for the respondent.

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.

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