- 2 -
1990 24,146 4,829
1991 39,162 7,832
The deficiencies result from respondent's determination that
petitioners are not entitled to deductions to the extent claimed
for Schedule E rental losses, miscellaneous employee business
expenses, charitable contributions, and investment interest. The
accuracy-related penalty is based on respondent's determination
that petitioners were negligent with respect to the preparation of
their tax returns. For the reasons that follow, we sustain
respondent's determinations in all respects.
All section references are to the Internal Revenue Code in
effect for the years under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT1
Petitioners, husband and wife, resided in Sacramento,
California, at all relevant times, including the time they filed
their petition. They filed joint Federal income tax returns for
each of the 3 years under consideration.
Petitioner Henry Novick is a physician, specializing in
urology. Dr. Novick conducted his medical practice in corporate
form until 1986, at which time the corporation was dissolved.
During the years under consideration (1989-91), he was an employee
1 The stipulation of facts and the accompanying exhibits
are incorporated by this reference.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011