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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, unless otherwise
indicated.
After concessions,1 the sole issue for our consideration is
whether petitioners have shown entitlement to a deduction for
rent payments as ordinary and necessary business expenses under
section 162(a).
FINDINGS OF FACT2
Petitioners Michael Chin and Julie Hedrich Chin resided in
Corona, California, at the time their petition was filed in this
case. Michael Chin3 (petitioner) graduated from medical school
in 1984 and became licensed to practice medicine as both a
physician and surgeon in California on December 16, 1985.
Petitioner’s primary medical practice specialty is general
surgery, and his secondary practice specialty is vascular
surgery. During the years at issue, petitioner leased or
subleased two offices in Corona, California, and one office in
1 In the statutory notice of deficiency, respondent
determined accuracy-related penalties due to a gross valuation
misstatement under sec. 6662(h). Respondent conceded the sec.
6662(h) penalties in his posttrial brief.
2 The parties’ stipulations of facts are incorporated by
this reference.
3 Petitioner Julie Hedrich Chin is a party to this case by
reason of the fact that she filed joint Federal income tax
returns with Michael Chin for the years at issue.
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Last modified: May 25, 2011