- 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
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