- 3 -
Several concessions were made by the parties at trial. Some
of these concessions are noted in the opinion and are
particularized in respondent’s posttrial brief.
Petitioner is a medical doctor. During the years at issue,
he was employed in that capacity by the Department of Veterans
Affairs (the V.A.), an agency of the United States. He worked at
the V.A. hospital at Helena, Montana. In addition to holding a
medical degree, petitioner is an attorney. He was admitted to
the Montana State bar in April 2000.
For the 2 years at issue, petitioner’s salary with the V.A.
was $65,351 and $110,920, respectively, for 1999 and 2000. Those
amounts were reported as income on petitioners’ joint Federal
income tax returns for 1999 and 2000.
In addition to his full-time employment with the V.A.,
petitioner maintained in his home what he considered to be a
private medical practice and a law practice. In addition,
petitioner maintained what he considered to be a consultation
activity wherein he offered consultation services to doctors and
lawyers with respect to reciprocal medical and legal issues.
Petitioner also was available to appear before professional
groups to address such issues.
3(...continued)
therefore, the burden does not shift to respondent under sec.
7491. Higbee v. Commissioner, 116 T.C. 438 (2001).
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