- 28 - affd. 64 F.3d 1406 (9th Cir. 1995). The regulations authorize two types of disclosure under section 6662(b)(2): (1) Disclosure in attachments to the return, see sec. 1.6662- 4(f)(1), Income Tax Regs., and (2) disclosure on the return, see sec. 1.6662- 4(f)(2), Income Tax Regs. Petitioners did not file any separate disclosure statement; therefore, they must demonstrate that they adequately disclosed all relevant information on their tax returns. Petitioners assert that they adequately disclosed the items at issue on their 1991 and 1992 returns. The return for each year contained two Schedules C for businesses for which petitioner was identified as the sole proprietor, one for "William J. Fleischaker, M.D." for which the principal business was the provision of medical services and another for "Deborah Fleischaker, et al." for which the principal business was oil and gas production. On the Schedules C for petitioner's oil and gas production for 1991 and 1992, petitioner claimed legal and professional expenses of $439,871 for 1991 and $51,950 for 1992. None of the claimed legal and professional expenses were related to petitioner’s oil and gas production activity. Except for $11,149 of the fees claimed in 1992, the fees claimed as legal and professional fees from oil and gas production were for payments made by petitioner under his guaranty obligations forPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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