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Respondent determined deficiencies in Federal income taxes
of $1,061 and $408 and accuracy-related penalties of $212 and $82
under section 6662(a), respectively, for petitioners' 1991 and
1992 tax years.
The issues for decision are: (1) Whether home office
expenses incurred by Richard G. Cook (petitioner) in a trade or
business activity are allowable as deductions under section
280A(c)(1), and (2) if such expenses are not allowable, whether
petitioners are liable for the accuracy-related penalties under
section 6662(a). If the Court holds that the expenses at issue
are not deductible pursuant to section 280A(c)(1), the Court must
then consider petitioner's contention that the disallowance of
the subject expenses as deductions constitutes invidious
discrimination and a violation of due process under the U.S.
Constitution.
Some of the facts were stipulated. Those facts, with the
exhibits attached thereto, are so found and are incorporated
herein by reference. At the time the petition was filed,
petitioners' legal residence was Salt Lake City, Utah.
Petitioner is an attorney at law and, during the years at
issue, was engaged in the practice of law at Salt Lake City,
Utah. For the year 1991 and for the first 5 months of 1992,
1(...continued)
petitioners' motion. Respondent thereafter filed an answer of
general denial.
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