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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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