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physician, whether the Court has jurisdiction to make that
determination where the income was reported by a limited
liability company (LLC) that filed a petition in bankruptcy
subsequent to the years in issue, and whether a penalty under
section 6673 should be awarded to the United States. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in these findings by this reference.
Petitioner resided in Arizona at the time that he filed his
petition. His income tax liability for 1993 and 1994 was the
subject of litigation in this Court that was decided in a
Memorandum Opinion of this Court, George v. Commissioner, T.C.
Memo. 1999-381.
In June 1993, petitioner and Jimmy C. Chisum (Chisum) formed
Arivada Health Enterprises Trust (Arivada). Petitioner
transferred his osteopathic medical practice, which he formerly
operated as a sole proprietorship, to Arivada when it was formed.
The operations of Arivada in 1996 and 1997 were not significantly
different from the operations for 1993 and 1994. During 1996 and
1997, Arivada paid the personal expenses of petitioner for his
home and automobile.
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