- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011