Joon H. Chong and Youngcha Kim Chong - Page 10

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          where petitioner administered anesthesia to his patients, not at            
          his home office where he conducted billing and other activities.            
               The facts in this case are remarkably similar to the facts             
          in Soliman.  Consequently, it is difficult to seriously entertain           
          petitioners' argument that the application of Soliman in their              
          case should lead to a different result.  Accordingly, for the               
          reasons discussed in Soliman we find that the principal place of            
          petitioner's medical practice in 1992 was the hospital, not his             
          home office.  Consequently, we hold that petitioners are not                
          entitled to a home office deduction for the year 1992.                      
          Automobile Expenses                                                         
               Along with other items not in dispute and the home office              
          deduction discussed above, on the Schedule C related to his                 
          medical practice, petitioner claimed a $1,327.50 depreciation               
          expense deduction, and deducted other car expenses in the amount            
          of $3,287.85.  The deductions apparently relate to a 1989 Mazda             
          automobile placed in service in April of 1989.  According to                
          petitioners' return, 90 percent of the usage of the Mazda was               
          related to petitioner's medical practice.  Petitioner did not               
          explain, and it is not otherwise evident from the record, how he            
          computed the $3,287.85 car expense deduction.4  In the notice of            


          4In their petition, petitioners stated that "actual auto                    
          expenses rather than standard mileage should be allowed."  There            
          is no evidence in the record, however, regarding any actual car             
          expenses incurred by petitioner in connection with his medical              
          practice.                                                                   




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