Assaf F. Al Assaf and Rehab Assaf - Page 2

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          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’s              




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