petitioner's 1989 and 1990 Federal income taxes in the amounts of $2,092 and $2,190, respectively, and penalties pursuant to section 6662(a) in the amounts of $399 and $438, respectively. After concessions,2 the issues for decision are (1) Whether petitioner is entitled to home office deductions in the amounts claimed on his returns or in lesser amounts as determined by respondent; (2) whether petitioner is entitled to deduct legal fees; and (3) whether the accuracy-related penalties as determined by respondent should be sustained. At the time of filing the petition herein, petitioner resided in Damascus, Maryland. FINDINGS OF FACT During 1989 and 1990, petitioner was a research hydraulic engineer for the U.S. Army Corps of Engineers. In the spring of 1989, petitioner taught a course for the U.S. Army Corps of Engineers at Mississippi State University. Petitioner reported $44,368 and $42,256 as total wages on his 1989 and 1990 Federal income tax returns, respectively. On Schedule A of his 1989 return, petitioner claimed deductions for "Office Space" in the amount of $5,200, and "Legal Expense" in the amount of $3,600. On Schedule A of his 1990 return, petitioner claimed deductions 2 At trial, petitioner conceded the following adjustments: (1) Petitioner failed to report $909 and $1,188 in State income tax refunds on his 1989 and 1990 returns, respectively; (2) petitioner failed to report interest income in the amount of $43 and $101 on his 1989 and 1990 returns, respectively; (3) petitioner is not entitled to deduct personal sales tax in the amounts of $4,349 and $4,095 on his 1989 and 1990 returns, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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