- 3 -
1994. We hold they are.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated into our findings by this reference. At the time
the petition in this case was filed, petitioners were married and
resided in Tiller, Oregon.
The Dentistry Activity
Petitioner has been licenced to practice dentistry since
1967, and is licensed to practice in California, Michigan, and
Oregon. In addition to a consulting office in his home,
petitioner maintains dental offices in Grants Pass and Medford,
Oregon. Mrs. Zdun, who is a qualified dental assistant, assists
petitioner when he sees patients at their home office.
Throughout the years at issue, petitioner devoted 3 days a week
to his dental practice.
Petitioner practices what he calls holistic dentistry.
According to petitioner, an organic apple is a special fruit rich
in vitamins, antioxidants, and bioflavonoids that contribute to
the health of gums and oral tissues. Thus, he counsels his
2 At the end of trial, respondent moved orally to increase
the amount of the deficiency for each year if the Court found
that petitioner was self-employed. The Court denied this motion.
We hold, however, that to the extent the amount of each
deficiency is not increased, petitioners are liable for self-
employment tax on petitioner's self-employment income. See secs.
1401 and 1402.
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