-3- Background Petitioners G. Dastgir and Mary A. Qureshi, husband and wife, resided in Richmond, Virginia, at the time they filed their petition. Petitioners timely filed a joint Federal income tax return for 1984. G. Dastgir Qureshi (petitioner) is a physician. He received his education and training in internal medicine and hematology oncology at the Medical College of Virginia and Columbia University. In 1974, he joined the faculty of the Medical College of Virginia. At all relevant times, petitioner was an assistant professor at the Medical College of Virginia. In 1982, petitioners’ income was approximately $35,000. During the year under consideration, 1984, petitioner received wages of $77,916. FoodSource FoodSource, Inc. (FoodSource)4 is a California company that, during the period 1980-82, sold interests in controlled atmosphere refrigerated containers to various investors. The Budd Company of 3(...continued) see Noonan v. Commissioner, T.C. Memo. 1986-449, affd. without published opinion sub nom. Hillendahl v. Commissioner, 976 F.2d 737 (9th Cir. 1992), and Brand v. Commissioner, T.C. Memo. 1988- 194. 4 Beginning in May 1982, containers were sold by FoodSource Sales, Inc., a corporation wholly owned by David A. Dixon, who owned or controlled a majority of FoodSource’s stock. For simplicity, both FoodSource and FoodSource Sales, Inc. are referred to herein as FoodSource.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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