- 20 - confused about the nature and extent of his legal activities in 1991. Petitioner occasionally appeared in court in connection with his rental real estate activity, as well as with respect to rental houses owned by his children (which he managed). Oftentimes, petitioner was required to file lawsuits against his tenants to recover delinquent rental payments or to evict a tenant. On this record, substantially all of petitioner's legal activities during 1991 were in connection with his rental real estate activity in Maryland. Additionally, the canceled checks submitted by petitioner showing payments of expenses he alleges were "legal activity" expenses were claimed by petitioner on Schedule E of the 1991 return (as part of his rental real estate activity expenses) and were allowed by respondent.13 Petitioner failed to present any evidence, other than his own fragmented and self-serving testimony, to show that he performed any legal activities other than those performed in connection with his rental real estate activity. No evidence was presented that would tend to show that petitioner was engaged in the trade or business of a law practice in 1991, within the meaning of section 162. Moreover, petitioner presented no evidence to show that he incurred expenses, carrying on legal activities in 1991, in excess of the amounts allowed as 13 This indicates to the Court that petitioner, himself, considered his "legal activities" in 1991 to be a part of his rental real estate activity.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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