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for negligence only with respect to the disallowed medical center
losses and that petitioners were liable for the addition to tax
for substantial understatement of income tax.
Dr. Rao
Dr. Rao was born on May 14, 1946, in India. He graduated
from medical school in Kurnool, India, and finished his
internship in 1970. Dr. Rao "was very established * * * making a
lot of money" while he worked in India. Petitioners came to the
United States in 1975. Dr. Rao completed 5 years of training in
the field of child psychiatry at Brookdale Hospital.
Dr. Rao was married and had two children by 1980. He lived
in Bayside (Queens), New York, and was a full-time employee of a
hospital where he did his residency/fellowship training. From
1979 until the end of 1981, after finishing his residency/
fellowship training, Dr. Rao worked in at least two private
clinics in Queens doing consultation work in the field of
psychiatry.
Dr. Rao's Schedule C Income
During the years in issue, Dr. Rao worked as a psychiatrist
at his private practice office located in Mountain Lakes, New
Jersey, and as a member of the staff of Saint Clares-Riverside
Medical Center in Denville, New Jersey. Petitioners maintained
three bank accounts at Midlantic National Bank (Midlantic), a
money market account and a checking account, both used in
petitioner's psychiatric practice, and an account in the name of
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