ANESTHESIA SERVICE MEDICAL GROUP, INC. v. C.I.R.

No. 86-7291.

825 F.2d 241 (1987)

ANESTHESIA SERVICE MEDICAL GROUP, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided August 18, 1987.


Attorney(s) appearing for the Case

Raymond F. Zvetina, San Diego, Cal., for petitioner-appellant.

Gayle P. Miller, Washington, D.C., for respondent-appellee.

Before FERGUSON, BOOCHEVER and WIGGINS, Circuit Judges.


WIGGINS, Circuit Judge:

Taxpayer Anesthesia Service Medical Group, Inc. (ASMG) appeals from the Tax Court's decision finding deficiencies in its tax payments in the years 1974 to 1979. ASMG, a California medical professional corporation, created an irrevocable trust (Trust) to cover medical malpractice claims against its employees. ASMG on appeal disputes the Tax Court's disallowance of its deductions for payments to the Trust and the court's attribution of Trust...

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