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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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