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transfers are not payments to his patients. Petitioner has
provided no evidence of the amount of payments made from the
refund account to his patients. On the basis of the evidence in
the record, we are unable to reasonably estimate the amount of
such payments.
Petitioner paid the billing services between 11 and 14
percent of the amounts collected. During 1992 the billing
service collected a total of $70,889 ($52,732 deposited into
petitioner's main bank account plus $18,157 deposited into his
FIB Roseburg account). On his 1992 return, petitioner did not
deduct any amount for the billing fees he paid. We will allow
petitioner a $7,798 deduction (11 percent of the amounts
collected) for billing fees.
On his 1992 return petitioner reported $1,125 for supplies
and $1,250 for licenses and taxes. Petitioner stopped practicing
medicine by 1992 and has not shown that the State license fee and
miscellaneous expenses exceed the amounts deducted on his 1992
return.
Issue III. Whether Petitioner Is Entitled to an Embezzlement
Loss Deduction for the 1992 Taxable Year
Petitioner concedes the adjustments for alimony, the portion
of the adjustment related to payments to Ms. Stanbery,3 and the
adjustments for the rental expenses.
3Petitioner has made an advance payment of tax for the
adjustment related to the payments made to Ms. Stanbery.
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