Michael Chin and Julie Hedrich Chin - Page 9




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          Medical Society.  Even if petitioner was to rely on his brother             
          for patient referrals, these customary business steps were not              
          taken to attract clients in addition to the referrals.                      
               Most notably, petitioner fails to explain how he could have            
          conducted his medical practice at the Sherman Oaks Property while           
          failing to generate any revenue.  In 1994, petitioner reported              
          Schedule C gross receipts of $1,056,961.  None of these gross               
          receipts were shown to be derived from activity at the Sherman              
          Oaks Property.  Further, the Skin Service Club reported zero                
          gross receipts on its S corporation tax return.  If petitioner              
          had conducted his medical practice at the Sherman Oaks Property             
          at any time in 1994, such activity would have generated revenue             
          reportable on either petitioner’s Schedule C or the Skin Service            
          Club’s corporate return.                                                    
               Respondent concedes that the Skin Service Club conducted               
          some business activity at the Sherman Oaks Property during 1994.            
          However, the business activity was minimal at best, with zero               
          revenue and minimal expenses.  There is no evidence indicating              
          that petitioner was involved with the Skin Service Club’s                   
          business activity during 1994.                                              
               In 1997, none of petitioner’s $1,253,902 Schedule C gross              
          receipts were derived from activity at the Sherman Oaks Property.           
          Further, the Skin Service Club was dissolved before 1997, and the           
          Sherman Oaks Property was completely vacant for the entire year.            







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