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$34,080 for 1988, 1989, and 1990, respectively.4 Petitioner did
not carry medical malpractice insurance, and he had no receipts
to show that he paid the $16,101 he claimed for such insurance
for 1988. Petitioner did not keep a log for the car and truck
expenses he claimed.
For all quarters of 1988, 1989, and 1990, petitioner failed
to file employment tax returns and pay employment taxes for his
employees. Prior to 1985, petitioner filed employment tax
returns for his employees. Petitioner also failed to file
information tax returns reporting wages paid to his employees.
Dr. Beauchamp's Books and Records
Petitioner did not have a bookkeeper or maintain any formal
books for his medical practice. Petitioner summarized his
expenses for each year on a few sheets of paper. Petitioner
provided these papers to Mr. Jung as support for the Schedule C
expenses he claimed.
Petitioner kept patient billing records; however, he did not
provide these records to Mr. Jung or offer them into evidence at
trial.
Petitioner gave Mr. Jung all the Forms 1099 petitioner had
for 1989. The Forms 1099 showed that petitioner received
4 Petitioner concedes that he is not entitled to claim real
estate activity expenditures as medical practice COGS. In the
notice of deficiency, respondent allowed petitioner these amounts
of wages.
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