- 13 - Other 1,800 --- --- Depreciation 41,034 22,370 23,834 Total expenses $147,548 $79,845 $136,793 Net Loss ($102,548) ($33,045) ($32,243) Loss claimed ($102,548) ($25,000) ($25,000) For 1986 and 1987, the claimed losses relate solely to the medical center. For 1988, the claimed loss includes $10,105 of deductions for some undetermined rental activity. In her notice of deficiency, respondent allowed petitioners deductions equal to the gross income reported each year for the medical center. OPINION 1. Preliminary Matters Respondent on brief renews her objection to the admission into evidence of a 1995 video tape. The tape was authenticated at trial as representing the medical center's physical layout and equipment during the years in issue. We hold the tape is admissible. Petitioner moved to dismiss the civil fraud addition to tax. Our decision makes that motion moot. 2. Civil Fraud Issue A. Parties' Positions Respondent argues that Dr. Rao committed fraud in his admitted failure to include all of his income from his psychiatry practice. Respondent points out that Dr. Rao is a highly educated businessman. Respondent argues that Dr. Rao reported income only as reported on Forms 1099; lied to IRS agents aboutPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011