- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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