Anne R. Dugan - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as in effect for the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions by the parties, the sole issue for                   
          decision is whether petitioner is entitled to a business                    
          deduction for the cost of certain meals in the amount of $450 for           
          the taxable year 1994.  We hold that she is not.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts are incorporated into these findings by this           
          reference.  When the petition in this case was filed, petitioner            
          resided in Sunnyvale, California.                                           
               During 1994, petitioner was self-employed as a licensed                
          acupuncturist.  She maintained a business address in San Jose,              
          California, for all of 1994, and in Sunnyvale, California, for              
          part of the year.                                                           
               Petitioner shared office space at the San Jose address with            
          a chiropractor, Dr. Catherine Zimmerman, who used the office                
          Mondays, Wednesdays, and Fridays.  Petitioner used the office               
          Tuesdays and Thursdays.  Petitioner paid Dr. Zimmerman rent, and            
          they shared office expenses.  They also treated some patients in            








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