Benjamin H. Smith - Page 2

                                         - 2 -                                        

                                        Accuracy-Related Penalty                      
          Year           Deficiency          Sec. 6662(a)                             
          1992           $3,122              $624                                     
          1993      3,138                    628                                      
               The Court must decide:  (1) Whether petitioner is entitled             
          to deduct Schedule C expenses; (2) whether petitioner is entitled           
          to additional itemized deductions; (3) whether petitioner is                
          entitled to deduct rental expenses; and (4) whether petitioner is           
          liable for the accuracy-related penalties under section 6662(a).            
               Some of the facts have been stipulated and are so found.               
          Petitioner resided in New York, New York, when his petition was             
          filed.                                                                      
               During the taxable years in issue, petitioner was a teacher            
          for the New York City Board of Education.  Petitioner also was an           
          attorney admitted to practice in the State of Connecticut.                  
          Petitioner's solo law practice was located in Bridgeport,                   
          Connecticut.  During 1992 and 1993, petitioner was involved in              
          the litigation of two civil cases on a contingency-fee basis.               
          One case involved a medical malpractice claim in which petitioner           
          claimed his client sought damages, and the case eventually was              
          settled for $70,000 in 1995.  The other case involved a personal            
          injury claim against the State of Connecticut.  The amount of               
          damages sought was $248,000.                                                
               On his Form 1040, U.S. Individual Income Tax Return,                   
          petitioner reported $32,281 in 1992 and $37,030 in 1993, in gross           






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

Last modified: May 25, 2011