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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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