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references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Petitioner resided in
Alta Loma, California, when he petitioned the Court.
Petitioner is a nurse anesthetist. Petitioner rendered
nurse anesthetist services on behalf of a partnership called
Newport Anesthesia Associates (NAA) for approximately 30 to 40
hours a week for 10 to 15 months during the years in issue.
Since 1987, NAA has operated as a partnership, using petitioner's
address as its address. The partnership agreement was entered
into between Renato Oania (Oania) and James C. Estrada CRNA Trust
(CRNA Trust) and was signed by Oania and petitioner; petitioner
signed the partnership agreement on behalf of the CRNA Trust.
Petitioner and Oania are the only people who have worked for and
administered anesthesia for NAA.
Dr. Peter J. Voloshin (Dr. Voloshin) has worked as a plastic
surgeon since 1986. During 1991 and 1992, Dr. Voloshin operated
a business entitled Newport Institute of Surgery, P. James
Voloshin, M.D., Inc. (NIS). Dr. Voloshin's business maintained
operating room facilities and required the services of a nurse
anesthetist.
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Last modified: May 25, 2011