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not provide a private office for petitioner's use, but he did
have access to a telephone, and could make and receive telephone
calls on a limited basis at the hospital. He also had access to
an area where he could do some paperwork. He was entitled to use
the physicians' lounge at the hospital, but due to the activity
normally going on in the lounge, he could not do any paperwork
there.
On occasion petitioner would be contacted directly by a
patient in need of his services; however, the majority of
petitioner's patients were referred to him by surgeons or by the
hospital. He was compensated by his patients on a fee for
service basis. Fee, billing, and payment arrangements were made
directly between petitioner and his patients. For the year 1992,
petitioner reported the income earned and expenses incurred in
connection with his medical practice on a Schedule C.
Petitioner administered anesthesia to patients scheduled to
undergo various surgical procedures at the hospital. In addition
to the services petitioner provided to patients at the hospital
during surgery, he would spend time with patients before and
after surgery in order to assess, and presumably reduce, the risk
of postoperative complications. During 1992, petitioner
administered anesthesia to patients at the hospital on 626
occasions, which required his presence there for approximately
1,000 hours.
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