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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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