17- -
reimbursement, because of the broken pipes in their kitchen. The
claim is separate and apart from the claimed casualty losses due
to flood damage that year.
Petitioners calculated the $12,566.62 claimed loss to their
kitchen pipes by totaling the amount they claim to have spent
repairing the damage caused by the broken pipes. They received
an invoice and a statement totaling $2,175.72 for repairs
performed as a result of their broken kitchen pipes.
Washington County, Mississippi, the county in which
petitioners lived in 1991, was declared a Presidential disaster
area as a result of the floods in February and April of 1991. At
trial, petitioners claimed that they are entitled to relief under
section 165(i) with respect to casualty losses suffered by them
during 1991.
Claimed Deductions for Legal and Professional Expenses
On Schedule C of their Federal income tax returns for 1990
and 1991, petitioners claimed deductions for business legal
expenses of $10,000 in 1990 and $13,000 in 1991. In respondent's
notice of deficiency the claimed business expense deductions for
legal fees were disallowed on the ground that petitioners had not
established that they constituted ordinary and necessary business
expenses.
Beginning in 1989, Mrs. Oliver was represented by John D.
Delgado, an attorney, in a criminal case which arose out of her
activity of keeping the books of Dr. Oliver, a physician.
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011