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For each year in issue, the issues for decision are: (1)
Whether petitioner is entitled to various deductions claimed on a
Schedule E, Supplemental Income and Loss; (2) whether petitioner
is entitled to an itemized deduction for medical expenses; and
(3) whether any underpayment of tax required to be shown on
petitioner’s income tax return is due to negligence.
Background
Some of the facts have been stipulated and are so found.
During all relevant times, petitioner was married to Elizabeth A.
Saunders. For each year in issue, petitioner filed his timely
Federal income tax return as a married individual, filing
separately. At the time the petition was filed, petitioner
resided in Evendale, Ohio.
During the years in issue, petitioner, an attorney licensed
in Massachusetts, was employed as a consultant for Arthur
Andersen LLP; his spouse was employed as a school teacher.
In 1978, petitioner and his spouse purchased a house in
Pepper Pike, Ohio (the Pepper Pike residence). Pepper Pike is a
suburb of Cleveland, Ohio, where petitioner was employed at the
time. From 1978 until at least December 1990, the exclusive use
of the Pepper Pike residence was as a residence for petitioner,
his spouse, and, until each moved out, their three children.
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