- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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