- 3 - 7. Whether petitioner is liable for accuracy-related penalties for 1995 and 1996. We hold that she is. Adjustments in the notice of deficiency relating to the self-employment tax, the related deduction under section 164(f), the deductible amount of petitioner’s medical expenses, and the earned income credit are purely mechanical matters, the resolution of which is dependent on our disposition of the disputed issues. Background Some of the facts have been stipulated, and they are so found. Petitioner resided in Ponte Vedra Beach, Florida, at the time that her petition was filed with the Court. During the years in issue, petitioner was a self-employed marketing consultant. Petitioner offered advertising and marketing services to a clientele consisting principally, if not exclusively, of medical doctors. During 1995, petitioner’s principal client was Dr. Elliott Jacobs (Dr. Jacobs), a plastic surgeon in New York City. During 1996, Dr. Jacobs was petitioner’s only client. Petitioner publicized and promoted Dr. Jacobs’ medical practice by, among other ways, placing periodic advertisements in the New York Post. Dr. Jacobs compensated petitioner for her services, and he reimbursed her for the cost of thePage: 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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