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Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession by petitioner, the issues remaining for
decision are: (1) Whether petitioner failed to report income;
(2) whether petitioner is entitled to depreciation deductions;
(3) whether petitioner is entitled to rental expense deductions;
(4) whether petitioner is entitled to claim his mother and his
father as his dependents; (5) whether petitioner is entitled to
head of household filing status; and (6) whether petitioner is
liable for the accuracy-related penalty under section 6662.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided in Washington,
D.C. During the first 6 months of 1991, petitioner was chief
resident at Washington Hospital Center. For the last 6 months of
1991, petitioner was in a private medical practice.
World Medical/Dental--Equipment Leasing and Depreciation
Petitioner purchased various medical and dental equipment,
office furniture, and a used neon sign during 1987, 1988, and
1989. During 1989, 1990, and at least a portion of 1991,
petitioner's mother operated World Medical/Dental, a walk-in
dental clinic on 16th Street, N.W., in Washington, D.C. Pursuant
to a lease agreement dated July 1, 1987, petitioner's mother was
to pay $2,500 per month for the use of the medical and dental
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