W. Bradford Davis and Tedde M. Rinker - Page 17

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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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