Kondamodi S. Rao and B. Satyaveni Rao - Page 4

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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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