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under a claim of right". Petitioner's claimed deduction in 1991
of $14,714 for "repayment under a claim of right" related to
litigation, which was resolved in 1991, over child support for
petitioner's daughter. In resolution of the litigation,
petitioner claimed to have paid approximately $12,000 in child
support, and the remaining $2,000 was claimed to have been paid
for attorney's fees and expenses of litigation.
The $5,000 petitioner deducted in 1991 for "expenses/legal
fees to collect taxable income" related to litigation instituted
by petitioner regarding the denial to him of unemployment
compensation by the State of Alabama. Petitioner's claimed
deduction is stated by petitioner to consist of legal fees,
reporters' transcripts, depositions, court fees, Federal Express
mailing, and administrative costs. Petitioner was unsuccessful
at all stages of the unemployment compensation litigation.
On Schedule A of his Federal income tax return for the
taxable year 1992, petitioner claimed itemized deductions as
follows:
Deduction Amount
State and local income taxes $963
Real estate taxes 740
Auto registration tax 20
Home mortgage interest 4,070
Gifts to charity 500
Casualty/theft loss 350
Moving expenses 1,200
Total 7,843
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Last modified: May 25, 2011