James Tinnell - Page 17




                                       - 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.                                                      





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