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.
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