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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.
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