Alec Jeffrey Megibow - Page 3

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          this adjustment, suffice it to say that our holding infra with              
          respect to the Schedule C expenses, and the rationale therefor,             
          apply equally to these Schedule A expenses.  Certain additional             
          adjustments made by respondent to petitioner’s itemized                     
          deductions, exemptions, and self-employment tax are correlative             
          in nature and will be resolved by our holdings on the foregoing             
          issues.                                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  At the time the petition            
          was filed in this case, petitioner resided in New York, New York.           
               Petitioner, a physician, timely filed Forms 1040, U.S.                 
          Individual Income Tax Return, for 1997, 1998, and 1999.  On each            
          of these returns, petitioner reported wage income from New York             
          University (NYU) Medical Center and attached corresponding Forms            
          W-2, Wage and Tax Statement.  The amounts so reflected totaled              
          $231,959.95, $248,625.68, and $305,592.93, for 1997, 1998, and              
          1999, respectively.  Petitioner also included with each return a            
          Schedule C for a “MEDICAL PRACTICE” with the stated name of “ALEC           
          MEGIBOW”.  The Schedules C reported the income, expense                     
          deductions, and net losses set forth below:                                 









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