Bruce K. Remy and Gail E. Remy - Page 4

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             to each of petitioners' joint income tax returns for 1990,               
             1991, and 1992 is a Schedule C, Profit or Loss From                      
             Business, designated "Ambulatory Medical Clinic".  On each               
             Schedule C, petitioners claimed a deduction for advertising              
             expenses which included the telephone services described                 
             above.  The advertising deductions claimed on their                      
             Schedules C, and the portion of each deduction attributed                
             to petitioner's telephone services are as follows:                       

             Tax        Advertising          Portion for                              
             Year        Deduction        Telephone Services                          
                 1990      $6,448          $3,328                                     
                 1991      16,535          15,600                                     
                 1992            18,141               17,169                          
                           41,124          36,097                                     

                  The deductions claimed for telephone services did not               
             involve an outlay of cash or property by petitioners, but                
             are based upon the value Dr. Remy ascribed to the                        
             professional services for which he was not compensated.                  
             Petitioner computed the value of the telephone services                  
             deducted in 1990 by estimating the number of telephone                   
             calls he received during the year, and multiplying that                  
             number by $15, a minimum charge for his medical services.                
             Petitioner computed the value of the telephone services                  
             deducted in 1991 by estimating the number of calls he                    







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