Eric Test and Delia Braun - Page 2




                                        - 2 -                                         
          petitioners are deductible as Schedule C business expenses or as            
          Schedule A miscellaneous itemized deductions, and (2) whether               
          petitioners are liable for the accuracy-related penalty under               
          section 6662(a).                                                            
                                  FINDINGS OF FACT2                                   
               Petitioners resided in Redwood City, California, at the time           
          they filed their petition.  Petitioners filed a joint Federal               
          income tax return for the 1994 tax year.                                    
               Odelia Braun (petitioner) is a medical doctor, who in 1985             
          was hired as an Associate Physician Diplomate and Assistant                 
          Clinical Professor of Medicine at the University of California,             
          San Francisco (UCSF).  When petitioner began working at UCSF, she           
          was responsible for patient care in the emergency room and for              
          training residents and medical students.  Petitioner acquired an            
          interest in the aspect of emergency medicine that was provided              
          before the patient arrived at the hospital; i.e., the care that             
          was rendered by paramedics and firefighters.                                
               From 1985 through 1987, petitioner undertook a study of                
          cardiac arrest emergency response systems in San Francisco,                 
          California, and around the United States.  Petitioner, with the             
          assistance of paramedics and firefighters, collected medical data           
          on all patients who suffered cardiac arrest in San Francisco and            


               2 The stipulation of facts and the exhibits attached thereto           
          are incorporated herein by this reference.                                  





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

Last modified: May 25, 2011