Ophthalmologist Can’t Make Tax Court See Everything His Way

Ophthalmologist Can’t Make Tax Court See Everything His Way

U.S. Tax Court

The Tax Court held that justice requires modification of the capital gains stipulations in an ophthalmologist’s deficiency case to avoid double counting and allowed some deductions under <a href="/lr/resolve//1lv6n">Cohan v. Commissioner</a>, 39 F.2d 540 (2nd Cir. 1930); the court held him liable for self-employment tax on partnership income and additions to tax for failure to timely file.

The Tax Court held that justice requires modification of the capital gains stipulations in an ophthalmologist’s deficiency case to avoid double counting and allowed some deductions under Cohan v. Commissioner, 39 F.2d 540 (2nd Cir. 1930); the court held him liable for self-employment tax on partnership income and additions to tax for failure to timely file.

The Tax Court held that justice requires modification of the capital gains stipulations in an ophthalmologist’s deficiency case to avoid double counting and allowed some deductions under Cohan v. Commissioner, 39 F.2d 540 (2nd Cir. 1930); the court held him liable for self-employment tax on partnership income and additions to tax for failure to timely file.

Sec. 162 Trade or business expenses

Sec. 274 Disallowance of certain entertainment, etc., expenses

Sec. 179 Election to expense certain depreciable business assets

Sec. 1366 Pass-thru of items to shareholders

Sec. 702 Income and credits of partner

Sec. 6651 Failure to file tax return or to pay tax

United States

Capital gains and losses

Employment taxes

Exemptions and deductions

Individual income taxation

Penalties

James S. Halpern

United States Tax Court

DOC 2020-19343

2020 TPR 21-20

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Ophthalmologist Can’t Make Tax Court See Everything His Way