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for the cost of a sales course, as well as for other expenses
associated with the course.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided in Sacramento,
California.
In 1974, while petitioner was driving his truck in the
conduct of his business, his truck was struck by a California
Highway Patrol (CHP) car. Petitioner sought advice from an
attorney about the possibility of filing a personal injury suit
against the CHP. Petitioner wanted to seek monetary damages for
injuries he received from the accident. After determining that
the possibility of recovery of damages was slight, petitioner did
not pursue the action any further. Petitioner incurred expenses
of $384 for the attorney's services. Petitioner deducted these
legal expenses on his 1976 Federal income tax return. Respondent
disallowed this deduction.
During 1976, petitioner began his own business selling meat
and seafood. Petitioner rented a house located at Bridgeford
Drive in Sacramento, California (the Bridgeford property), to use
for his business. Petitioner used the Bridgeford Drive address
for his personal and business checking accounts. On his 1976
return, petitioner deducted as a business expense 100 percent of
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