- 2 - activity losses incurred by their wholly owned limited liability company. We hold that they do 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 Oklahoma City, Oklahoma, at the time they filed the petition. Petitioner wife was a partner in the law firm of Assaf & Cohlmia, PLLC (the law firm), in Oklahoma City, Oklahoma, during the years at issue. During the same time, petitioner husband was a medical doctor and worked full-time as a professor at the University of Oklahoma Health Sciences Center in Oklahoma City, Oklahoma. Petitioner husband also provided consulting services to his wife’s law firm, other attorneys, and health maintenance organizations. The services he provided included reviewing medical-malpractice cases, serving as an expert witness, performing mock surveys, and providing training in quality assurance programs. Petitioner husband engaged in the consulting activity as a part of a professional practice plan within the University of Oklahoma Health Sciences Center, which allowed its professors to pursue business activities outside the University relating to their area of expertise. Petitioners conducted their respective practices in the same office building (the office building). The office building was owned by AGI Consulting, LLC (AGI), in which petitioners were each 50-percent shareholders. Petitioner husband’s consulting activities were conducted through AGI, while petitioner wife’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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