- 2 - $491,054 as a business bad debt deduction under section 1661 in 1995. We hold they are not. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the accompanying exhibits are incorporated by this reference. Petitioners resided in Louisville, Kentucky, at the time they filed the petition. Petitioner Maurice E. John, Jr. (petitioner), is an eye surgeon and ophthalmologist who has continuously engaged in the practice of medicine since 1975. Since 1981, petitioner has provided medical services as a full-time employee of John Eye Clinic, Inc. (the Clinic), a professional corporation incorporated in Jeffersonville, Indiana. Petitioner was, at nearly all times, the 100-percent shareholder of the Clinic. Evans Petitioner hired John Evans (Evans) in 1987 to serve as the Clinic’s business manager. Petitioner chose Evans from a pool of candidates because “he was by far the most impressive and best candidate.” Throughout their acquaintance, petitioner was highly impressed with Evans’ performance and abilities, describing him as “incredibly bright” and one of the “smartest people [he had] ever met”. Petitioner felt that Evans “was an asset to the 1All section references are to the Internal Revenue Code in effect for the year at issue, unless otherwise indicated, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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