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been that of one of the several ventures entered into by
petitioner’s brother.5 Petitioner’s rent payments were personal
expenditures unrelated to his medical practice and designed to
support his brother’s business interests while shifting income to
his mother, who was in a lower tax bracket.
To the extent not herein discussed, we have considered all
other arguments made by the parties and conclude that they are
moot or without merit.
To reflect the foregoing and concessions of the parties,
Decision will be entered
for respondent.
5 Petitioner did not argue that the rent payments were a
type of investment or contribution of capital in the Skin Service
Club entitling him to deductions for one-half of the rent
payments via the S corporation pass-through rules.
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Last modified: May 25, 2011