3 (2) Whether petitioners may deduct legal expenses of $10,243 in 1986, $59,352 in 1987, and $104,156 in 1988. We hold that they may, subject to the 2-percent limit in section 67. Unless otherwise indicated, section references are to the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioners Petitioners Stephen F. Scofield (petitioner) and Nancy E. Scofield (Mrs. Scofield) are married and lived in Marietta, Georgia, when they filed their petition. Petitioners have been married since 1981 and have four sons. Petitioner graduated from Syracuse University in 1968 with a degree in economics. He started to work in the newsprint industry that year. He worked for Great Northern Paper Co. (Great Northern) from 1968 to June 1972, primarily in sales positions. Petitioner then worked for about 4 years as sales manager for Eastern Color Printing Co. (ECP), a printing business. B. Petitioner's Businesses 1. Unidyne Petitioner left ECP around 1976 to start a company which he named Unidyne, Inc. (Unidyne). Unidyne was in the paperPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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