- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011