- 4 - accounting or tax return preparation. On his Schedules C for 1988, 1989, and 1990, petitioner listed his principal business or profession as "Med. Doctor & Home Construction Co", "Medicing [sic] & Construction", and "Med. Doctor & Contractor", respectively. On each return there was only one Schedule C. Petitioner reported $261,269, $270,658, and $317,334 in gross receipts from his medical practice for 1988, 1989, and 1990, respectively. Petitioner determined his gross receipts for the years in issue by totaling the amounts reported to him by Form 1099 payors. During the audit of petitioner in 1991 (the audit), he told Revenue Agent Harold Jung (Mr. Jung) that 99.9 percent of his patients paid for medical services through insurance, Medicare, or Medi-Cal; therefore adding up the Forms 1099 was the most appropriate way to determine his gross receipts. Petitioner claimed various items on Schedule C of his tax returns. As costs of goods sold3 (COGS) of his medical practice, petitioner claimed expenditures for capital improvements to real property and wages paid in the amounts of $31,176, $38,368, and 3 The use of the term "cost of goods sold" is for convenience only and does not imply a finding that such amounts were cost of goods sold.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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