Victor I. Rosenberg and Deborah I. Rosenberg - Page 3




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               4. Whether petitioners’ advances to Cabana Boy were made               
          to promote Dr. Rosenberg’s medical practice and thus are                    
          deductible by petitioners as advertising or promotional expenses.           
          We hold that they are not.                                                  
               Section references are to the Internal Revenue Code in                 
          effect for the years in issue.  Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
          A.   Petitioners                                                            
               Petitioners Victor I. Rosenberg (Dr. Rosenberg) and Deborah            
          I. Rosenberg (Mrs. Rosenberg) lived in New York, New York, when             
          they filed the petition.  Dr. Rosenberg has been a plastic                  
          surgeon since 1970.  Petitioners' residence and Dr. Rosenberg's             
          medical practice were located at the same address in New York               
          during the years in issue.  Almost all of Dr. Rosenberg’s income            
          was from his medical practice.  Mrs. Rosenberg worked in Dr.                
          Rosenberg’s medical office until 1986.                                      
               Before and during the years in issue, Dr. Rosenberg                    
          continuously sought publicity for his plastic surgery practice in           
          periodicals and on television.  He advertised in New York.                  
          Before 1986, articles about plastic surgery that mentioned or               
          featured Dr. Rosenberg appeared in the New York Daily News, the             
          New York Times, the New York Post, Lifestyles, the National                 
          Enquirer, Vogue, Cosmopolitan, Bazaar, Every Woman, Prime Time,             






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