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stall barn, riding arena for horses, pasture land, and an acre of
trail and woods.
Petitioner Barry Hillman (Dr. Hillman) was 64 years old at
the time of trial and a medical doctor. During the years at
issue and continuing through the time of trial, Dr. Hillman
operated a medical practice in Columbus, Ohio, as a sole
practitioner with three employees. Petitioner Yvonne Hillman has
assisted Dr. Hillman in his medical practice as an office worker
since 1969. During the years in issue, Mrs. Hillman was Dr.
Hillman’s office manager and kept the books for his medical
practice. She was paid $3,600 in annual wages during 1993 and
1994 for which she was issued Forms W-2. Petitioners provided
Mr. Adelman with all original checks, deposit slips, and
financial records for Dr. Hillman’s medical practice. In 1993
and 1994, Dr. Hillman devoted between 45 and 50 hours per week to
the practice.
On their 1991, 1992, 1993, 1994, 1995, and 1996 joint
returns,1 petitioners reported the following income and expenses
from Dr. Hillman’s medical practice on Schedule C:
1 Petitioners have reserved a relevancy objection with
respect to post-1994 exhibits. Sec. 1.183-2(a), Income Tax
Regs., directs consideration of “all of the facts and
circumstances” in determining whether an activity is engaged in
for profit, and evidence from years subsequent to the years in
issue is relevant to the extent it may create inferences
regarding the existence of a profit motive in the earlier years.
See, e.g., Hoyle v. Commissioner, T.C. Memo. 1994-592; Smith v.
Commissioner, T.C. Memo. 1993-140. We therefore overrule
petitioners’ relevancy objection.
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