Kondamodi S. Rao and B. Satyaveni Rao - Page 2

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          All section references are to the Internal Revenue Code in effect           
          for the years in issue.  All Rule references are to the Tax Court           
          Rules of Practice and Procedure.                                            
               Petitioner Kondamodi S. Rao, hereinafter referred to as Dr.            
          Rao or petitioner, omitted gross income from his sole                       
          proprietorship psychiatry practice in 1986, 1987, and 1988.                 
          Petitioners deducted losses on their joint Federal income tax               
          returns in 1986, 1987, and 1988 from the operation of Forest Park           
          Medical Center (the medical center).  After concessions, the                
          issues for decision are:                                                    
               (1)  Whether Dr. Rao1 is liable for the additions to tax for           
          fraud pursuant to section 6653(b)(1)(A) and (B) for 1986 and 1987           
          and section 6653(b)(1) for 1988;                                            
               (2)  whether petitioners have substantiated deductions from            
          the operation of the medical center for 1986, 1987, and 1988 in             
          amounts greater than that allowed by respondent; and, if so,                
               (3)  whether petitioners had amounts "at risk" under section           
          465 to enable them to deduct losses from the operation of Forest            
          Park Medical Center; and, if so,                                            
               (4)  whether the passive loss rules under section 469 either           
          restrict or disallow petitioners' losses from the operation of              
          the medical center;                                                         



               1  Respondent conceded the additions to tax for fraud for B.           
          Satyaveni Rao (Mrs. Rao) at trial.                                          




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