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$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.
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