Joon H. Chong and Youngcha Kim Chong - Page 2

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          determined a deficiency in petitioners' 1992 Federal income tax             
          in the amount of $2,860.                                                    
               The issues for decision are:  (1) Whether petitioners are              
          entitled to a deduction for a home office used by Joon H. Chong             
          in connection with his practice of medicine as a self-employed              
          anesthesiologist; and (2) whether petitioners are entitled to a             
          deduction in an amount greater than that already allowed by                 
          respondent for automobile expenses related to Joon H. Chong's               
          practice of medicine.  Issues resulting from other adjustments              
          made in the notice of deficiency to petitioners' itemized and               
          personal exemption deductions will automatically be resolved in             
          accordance with the resolution of the two issues referred to                
          above.                                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.  At the time that the                
          petition was filed in this case, petitioners resided in St.                 
          Joseph, Michigan.  References to petitioner are to Joon H. Chong.           
               Petitioner began practicing medicine in 1975.  During the              
          year in issue petitioner was a self-employed anesthesiologist,              
          licensed to practice in Michigan.  He held privileges to provide            
          services as an anesthesiologist at Mercy Memorial Hospital (the             
          hospital) in St. Joseph, Michigan.  Petitioner was neither an               
          employee of, nor compensated by, the hospital.  The hospital did            




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