- 15 - 4. Payments to Employees and Contractors Petitioners submitted exhibits with copies of canceled checks written by Dr. Rinker to several payees in 1999. Dr. Rinker testified that the checks represented payments from her to several people for legal, accounting, bookkeeping, and secretarial services rendered in connection with her medical practice. Some of the payments were made in exchange for secretarial and bookkeeping expenses which related directly to Dr. Rinker’s practice at that time; others were made in exchange for legal and business advice on a future venture proposed to Dr. Rinker by another doctor. According to Dr. Rinker’s uncontradicted testimony, the proposed venture never materialized and she ceased pursuing it. In her testimony, Dr. Rinker admitted that some of the checks in the exhibits were not for professional services at all and were mistakenly included. In addition, Dr. Rinker also admitted that she engaged the same people to do her personal and business bookkeeping and accounting. a. Fees for Advice on the Proposed Venture We conclude that Dr. Rinker’s payments to financial and legal advisers were not ordinary and necessary expenses of Dr. Rinker’s medical practice as it stood in 1999. The evidence does not establish that the proposed venture was related to Dr. Rinker’s current business. Petitioners are therefore notPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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