Richard G. Cook and Patricia A. Cook - Page 2

                                                 - 2 -                                                   

                  Respondent determined deficiencies in Federal income taxes                             
            of $1,061 and $408 and accuracy-related penalties of $212 and $82                            
            under section 6662(a), respectively, for petitioners' 1991 and                               
            1992 tax years.                                                                              
                  The issues for decision are:  (1) Whether home office                                  
            expenses incurred by Richard G. Cook (petitioner) in a trade or                              
            business activity are allowable as deductions under section                                  
            280A(c)(1), and (2) if such expenses are not allowable, whether                              
            petitioners are liable for the accuracy-related penalties under                              
            section 6662(a).  If the Court holds that the expenses at issue                              
            are not deductible pursuant to section 280A(c)(1), the Court must                            
            then consider petitioner's contention that the disallowance of                               
            the subject expenses as deductions constitutes invidious                                     
            discrimination and a violation of due process under the U.S.                                 
            Constitution.                                                                                
                  Some of the facts were stipulated.  Those facts, with the                              
            exhibits attached thereto, are so found and are incorporated                                 
            herein by reference.  At the time the petition was filed,                                    
            petitioners' legal residence was Salt Lake City, Utah.                                       
                  Petitioner is an attorney at law and, during the years at                              
            issue, was engaged in the practice of law at Salt Lake City,                                 
            Utah.  For the year 1991 and for the first 5 months of 1992,                                 

                  1(...continued)                                                                        
            petitioners' motion.  Respondent thereafter filed an answer of                               
            general denial.                                                                              




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011