Frank W. George - Page 12




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          E.   Petitioner's Income Tax Returns                                         
               Petitioner and Jones-George filed joint income tax returns              
          for 1991 and 1992.  They attached a Schedule C for petitioner's              
          medical practice to their 1991 and 1992 returns.  On it,                     
          petitioner reported that his business address was located at the             
          Scottsdale residence.  Petitioner reported that his medical                  
          income was self-employment income, and paid self-employment tax              
          with his 1991 and 1992 returns.                                              
               Petitioner filed his 1993 income tax return (Form 1040) on              
          August 11, 1994.  Petitioner and Jones-George filed separately               
          for 1993 because she believed that Arivada was not a valid trust.            
               Petitioner attached a Schedule C for his medical practice to            
          his 1993 return.  On it, he reported that he had $68,943 of gross            
          income, consisting of $900 from Accutrace, $14,138 from Clinic               
          Physicians Group, P.C., $49,905 from Doctors on Call, Inc., and              
          $4,000 from Arivada.                                                         
               Petitioner filed his 1994 income tax return on July 18,                 
          1995.  He attached a Schedule C for his medical practice.  On it,            
          petitioner reported that he had $15,136 of gross income,                     
          consisting of the following:  $736 from Cigna Healthcare                     
          Benefits, Inc., and $14,400 from Arivada.                                    
          F.   Notice of Deficiency                                                    
               On July 15, 1997, respondent issued a notice of deficiency              
          to petitioner for 1993 and 1994.  Respondent determined that                 






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