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Wildomar, California, to operate his medical practice. All three
offices were within Riverside County limits, and petitioner paid
aggregate rent for the offices of $31,760 in 1994 and $24,039 in
1997.
At all pertinent times petitioner maintained appropriate
State, county, and local licenses to conduct business at all of
his office locations in Riverside County and maintained hospital
privileges at several hospitals in Riverside County. Petitioner
also maintained both general business and surgical telephone
listings in three local Riverside County telephone directories
and was a member of the Riverside County Medical Association.
For the 1994 and 1997 tax years, petitioner reported on his
Schedule C, Profit or Loss From Business, gross receipts of
$1,056,961 and $1,253,902, respectively. All of these gross
receipts were derived from petitioner’s medical practice at the
three Riverside County offices. Further, for 1994 and 1997,
petitioner reported taxable income of $620,115 and $737,341,
respectively, and was in the 39.6-percent tax rate bracket.
In November 1989, petitioner’s mother, Chi Ying Chin,
acquired a commercial building at 13732 Ventura Boulevard,
Sherman Oaks, California (Sherman Oaks Property). Sherman Oaks,
California, is approximately 10 miles northwest of Los Angeles
and approximately 70 miles west of Riverside County.
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Last modified: May 25, 2011