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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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