- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011