W. Bradford Davis and Tedde M. Rinker - Page 20

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          8.  Supplies                                                                
               Petitioners presented an exhibit listing expenses for                  
          patient supplies incurred in connection with Dr. Rinker’s medical           
          practice.  The exhibit contained some of Dr. Rinker’s financial             
          records, invoices from a company named MedQuest Pharmacy, and two           
          checks written by Dr. Rinker.  The exhibit showed total                     
          expenditures of $8,117.80.  Dr. Rinker testified that the records           
          related to purchases of drugs and hormones for her patients.  At            
          trial, Dr. Rinker admitted that one of the two checks in the                
          exhibit was miscategorized and actually represented a personal              
          medical expenditure.  The other check appears to duplicate a                
          payment recorded on one of the invoices.                                    
               A doctor’s expenditures for her patients’ medical supplies             
          are deductible under section 162.  Sec. 1.162-6, Income Tax Regs.           
          Eliminating the payment for personal medical supplies and the               
          duplicate payment, we allow a deduction of $6,801.11 for Dr.                
          Rinker’s purchases from MedQuest.                                           
               Petitioners also presented an exhibit purporting to                    
          substantiate office expenditures Dr. Rinker incurred during 1999.           
          This exhibit contained canceled checks that Dr. Rinker wrote out            
          to various payees, including consumer retailers such as Costco              
          and Office Depot, during 1999.  The checks contained the                    
          following information:                                                      







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