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All section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure. After concessions, the
issues for decision are as follows:
1. Whether petitioner is entitled, pursuant to section
165(c)(3), to casualty loss deductions for 1993 and 1994. We
hold that he is not.
2. Whether petitioner is liable for additions to tax for
failure to file Federal income tax returns for 1993 and 1994. We
hold that he is.
3. Whether petitioner is liable for additions to tax for
failure to remit estimated tax payments for 1993 and 1994. We
hold that he is.
Some of the facts have been stipulated and are so found.
Petitioner is a self-employed medical doctor licensed to practice
in Illinois, Indiana, and Iowa. He resided in Chicago, Illinois,
at the time the petition was filed. During the years in issue,
petitioner received income from Medical Doctor Associates, Inc.,
and Gibson General Hospital, each of which issued Forms 1099
reflecting such income as nonemployee compensation. Petitioner
also received interest income, for which Forms 1099 were issued.
None of these payors withheld taxes.
Petitioner did not file Federal income tax returns for
either of the years in issue. He did, however, file extension
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