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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.
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