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Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s 1999
Federal income tax in the amount of $8,788 and a penalty under
section 6662(a) in the amount of $1,755.60.
Petitioner conceded that he (1) received long-term capital
gain income in the amount of $1,154 in 1999, (2) received $11,154
from Social Security, (3) received interest income in the amount
of $155 in 1999, (4) is liable for an addition to tax for 1999
pursuant to section 6651(a)(1) and (5) is liable for a penalty
under section 6662(a). After concessions by petitioner, this
Court must decide whether petitioner is entitled to a deduction
for expenses from Schedule C, Profit or Loss From Business, in
the amount of $28,780.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Los Angeles, California, at the
time he filed his petition.
Petitioner is 86 years old, is an attorney, and is currently
an active member of the State Bar of California. Petitioner
graduated from Harvard Law School in 1944. He has been engaged
in the practice of law for 60 years.
In 1999, petitioner was a lawyer operating as a sole
proprietor. On occasion, he used the Sax-Brook Structural
Building Systems, Inc. (Sax Brook) name for his own purposes.
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Last modified: May 25, 2011