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exhibits was mistakenly included and did not represent a payment
for professional or office services.
The checks for secretarial services related to Dr. Rinker’s
medical practice amount to $1,442. Petitioners are entitled to a
deduction under section 162 for that amount.
The checks for bookkeeping and accounting services add up to
$2,582. Dr. Rinker testified that she paid some of these amounts
for services performed for her medical practice, but petitioners
offered no evidence as to what portion of the payments related to
services performed for her in her personal capacity. On the
basis of Dr. Rinker’s testimony, we believe that at least half of
the fees related to Dr. Rinker’s medical practice. Under Cohan
v. Commissioner, 39 F.2d at 544, we allow a deduction of $1,291.
5. Medical Management Solutions
Dr. Rinker testified that she engaged an outside billing
service called Medical Management Solutions to collect and manage
payments from medical insurance companies. At trial, petitioners
presented an exhibit listing payments to Medical Management
Solutions. Petitioners also presented an additional check made
out by Dr. Rinker to the company which was not included in the
exhibit. The payments to Medical Management Solutions for
billing services are deductible business expenses under section
162. We therefore allow a deduction for the amounts shown by the
exhibit and the additional check, totaling $11,300.
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