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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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Last modified: May 25, 2011