Richard H. Daley and Estate of Anne H. Daley, Deceased, Richard H. Daley, Executor - Page 3

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               Petitioner has practiced medicine as a surgeon in Arizona              
          since 1967.  His medical practice requires between 50 and 60                
          hours of his time each week.  During the 12-year period ending              
          with 1992, petitioner's average wage income from his medical                
          practice was $266,507.  Similarly, during the taxable years at              
          issue, petitioner's average wage income from his medical practice           
          was $299,687.  Petitioner has always relied on a professional               
          accountant to manage the books and records of his medical                   
          practice.                                                                   
               During the years 1972 through 1986, petitioner was a partner           
          in M.L. Leasing, a partnership engaged in the leasing of various            
          types of goods.  In 1987, this partnership was dissolved and                
          petitioner began operating M.L. Leasing as a sole proprietorship.           
          Petitioner continued to operate M.L. Leasing as such through at             
          least March 1994.  M.L. Leasing's books and records were managed            
          by a professional bookkeeping service.  During taxable years 1983           
          through 1992, petitioner reported the following profits and                 
          losses from his interest in M.L. Leasing:3                                  
               Year                Profit (Loss)                                      
               1983                    $7,270                                         
               1984                    1,280                                          
               1985                    7,565                                          
               1986                    (2,000)                                        
               1987                    9,283                                          
               1988                    4,429                                          

               3Until 1987, M.L. Leasing was a partnership.  Accordingly,             
          the amounts reflected for years prior to 1987 indicate                      
          petitioner's share of partnership profit and losses.                        




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