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 Next
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