Bruce K. Remy and Gail E. Remy - Page 2

                                        - 2 -                                         
             Penalty                                                                  
             Year        Deficiency                    Sec. 6662                      
                         1990        $470              $270                           
                         1991        4,345             1,114                          
                         1992        5,320             1,428                          

             All section references are to the Internal Revenue Code,                 
             as in effect during the years in issue.  We are called upon              
             to decide three questions:  First, whether petitioners can               
             deduct the value of certain uncompensated medical services               
             that Dr. Remy provided to his patients, as an advertising                
             expense under section 162; second, whether the subject tax               
             deficiencies should be disallowed on the ground that the                 
             original revenue agent's report contained "gross errors of               
             fact"; third, whether petitioners are liable for the                     
             accuracy-related penalty under section 6662(a).                          

                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated by the parties.              
             The stipulation of facts, the supplemental stipulation of                
             facts, and the exhibits attached thereto are hereby                      
             incorporated in this opinion.  At the time the subject                   
             petition was filed in this Court, petitioners resided in                 
             the State of Oklahoma.  In this opinion, references to                   
             petitioner are references to Dr. Bruce K. Remy.                          








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