Paul Arthur Zipp - Page 3

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               5.  Whether the assessment of a deficiency for the 1990                
          taxable year is barred by the statutory period of limitations.              
               6.  Whether petitioner is liable for the accuracy-related              
          penalty under section 6662(a) for the 1990, 1991, and 1992                  
          taxable years.                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               Petitioner is a licensed radiologist who resided in                    
          Roseburg, Oregon, when the petition in this case was filed.                 
          Petitioner received his bachelor's degree from the University of            
          California at Santa Barbara and his medical degree from the                 
          University of California at San Francisco.  He completed an                 
          internship and residency at the University of Colorado Medical              
          Center in Denver.  After completing his residency, petitioner               
          served in the U.S. Navy for 2 years.                                        
               From 1977 until 1983, petitioner was chief of the radiology            
          department at the Columbia District Hospital in St. Helens,                 
          Oregon, and also worked in the hospital's emergency room.                   
          Petitioner incorporated his practice in St. Helens.  Petitioner's           
          accountant recommended that he incorporate the practice so that             
          petitioner could keep his business separate from his personal               
          affairs and maximize his pension contributions.                             





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