John H. and Mary E. Douglas - Page 2

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          petitioners' Federal income taxes for 1992 and 1993 in the                  
          amounts of $6,503 and $174, respectively.                                   
               After concessions,2 the issues for decision are whether                
          petitioners are entitled to a bad debt deduction claimed on                 
          Schedule C of their 1992 return and whether petitioners are                 
          entitled to deduct legal expenses claimed on Schedule C of their            
          1992 and 1993 returns or whether said expenses are properly                 
          allowable as miscellaneous itemized deductions.                             
          Background                                                                  
               The facts have been fully stipulated.  The stipulation of              
          facts and the attached exhibits are incorporated herein by this             
          reference.  At the time of filing the petition, petitioners                 
          resided at Fort Washington, Maryland.                                       
               From March 1982 through December 1989, petitioner John H.              
          Douglas (hereinafter petitioner) purchased 11 residential                   
          properties.  During this period, petitioner renovated seven of              
          the properties and sold two of the properties.                              
               In May 1983, petitioner bought an improved lot in Fort                 
          Washington, Maryland (hereinafter Fort Washington property), for            


               1(...continued)                                                        
          Procedure.                                                                  
               2   Respondent conceded that petitioners are entitled to               
          Schedule A miscellaneous itemized deductions, after limitations,            
          in the total amount of $1,001 and $2,664 for years 1992 and 1993,           
          respectively.  This exceeds the amount allowed in the statutory             
          notice of deficiency by $541 and $1,121 for years 1992 and 1993,            
          respectively.                                                               




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