David E. and Cheryl G. Smith - Page 3

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          Whether petitioners' dog-breeding activity during the taxable               
          years 1990, 1991, and 1992 was engaged in for a profit; and (2)             
          whether any underpayment of tax is due to negligence or                     
          intentional disregard of rules or regulations.                              
                                  FINDINGS OF FACT                                    
               At all times relevant to this case petitioners were husband            
          and wife and resided in Los Gatos, California.  They filed joint            
          Federal income tax returns for all 3 years at issue.                        
               David Smith (Mr. Smith) is a medical doctor and was employed           
          as a vascular surgeon during the taxable years at issue at Good             
          Samaritan Hospital in San Jose, California.  Mr. Smith generally            
          worked 10 hours per day, 5 days a week as a physician.  In                  
          addition, he was required to be "on-call" as a physician every              
          third night and every third weekend.  Cheryl Smith (Mrs. Smith)             
          was not employed outside of petitioners’ household during the               
          taxable years at issue.                                                     
               Mr. Smith received wages from his medical practice totaling            
          $289,347, $278,419, and $242,960 for the taxable years 1990,                
          1991, and 1992, respectively.  In addition to the wages, Mr.                
          Smith received rental income from the leasing of medical                    
          equipment to Good Samaritan Hospital.  His net rental income was            
          $47,872, $51,957, and $38,405 for the taxable years 1990, 1991,             
          and 1992, respectively.  Petitioners also owned an agricultural             







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