- 17 - reported by Zila,20 and the additional discount for restrictions on stock taken by petitioner (marketability discount). The schedule contained the following statement concerning the marketability discount: THIS DISCOUNT TAKEN BECAUSE TAXPAYER FEELS THAT STOCK WOULD BE SEVERELY EFFECTED IF HE PUT ALL THESE SHARES ON MARKET IN ONE BLOCK. IN ADDITION TAXPAYER CANNOT SELL SHARES FOR THESE YEARS PER SEC REGULATIONS. THEREFORE, PRESENT VALUE IS LESS. Petitioner, however, did not make the disclosure on Form 8275, Disclosure Statement, or Form 8275-R, Regulation Disclosure Statement. Petitioner and respondent have agreed that petitioner is entitled to only a single discount of $282,979. C. Medical Practice From 1989 through 1998, petitioner reported income and losses from his medical practice as follows: Year Income (Loss) 1989 ($10,617) 1990 (15,235) 1991 (3,732) 1992 12,738 1993 36,723 1994 20,574 1995 10,547 1996 8,151 1997 5,449 1998 7,689 20The additional schedule indicated the amount of petitioner’s ordinary income as “ORDINARY INCOME-1099". We assume this indicates that petitioner’s ordinary income was reported on Form 1099.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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