- 3 - 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. AttachedPage: 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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