Bruce K. Remy and Gail E. Remy - Page 3

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                  Petitioner is a medical doctor.  During the years in                
             issue, he operated an ambulatory care medical clinic in                  
             Norman, Oklahoma.  As part of his practice, petitioner                   
             consulted with his patients by telephone.  From time to                  
             time, he also telephoned pharmacies to authorize the                     
             refilling of prescriptions on behalf of patients who                     
             requested him to do so.                                                  
                  Typically, petitioner did not charge his patients and               
             received no cash or other compensation for these telephone               
             services.  If petitioner felt that a patient was abusing                 
             this free service, he would either refuse to provide the                 
             service to the patient, or provide the service but ask the               
             patient to come to his office for an appointment.                        
                  Beginning on September 25, 1991, petitioner kept a log              
             of his telephone consultations with patients.  Each entry                
             in the log consisted of the name of the patient, the date                
             of the call, and a brief description of the nature of the                
             call.  For the period September 25, 1991, through the end                
             of 1991, there were approximately 190 entries in the log.                
             For tax year 1992, there were approximately 860 entries in               
             the log.                                                                 
                  During the years in issue, petitioners reported income              
             for Federal income tax purposes on the basis of the cash                 
             receipts and disbursements method of accounting.  Attached               






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