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providers generally gave a positive prognosis for his full
recovery. On the Schedule C attached to petitioner’s 1992 return,
petitioner reported no income from his paralegal/boat repair
business2 and claimed the following expenses:
Depreciation $1,222
Office expense 465
Pension and profit
sharing plans 35
Rent 3,600
Repairs and
maintenance 25
Storage 1,980
Trade books 916
Paralegal association 50
Total 8,293
As indicated earlier, the storage costs of $1,980 pertain to
his boat activity. The $35 for pension and profit sharing plans
was a maintenance fee for his Keogh plan. All of the other
expenses are directly related to petitioner’s paralegal activity.
Petitioner has adequately substantiated the above amounts, and
substantiation is not an issue in this case.
Because a possible remedy would be to dismiss this case in
favor of petitioner if we were to grant petitioner’s motion, we
will deal with the motion first. In his motion, petitioner
contends that respondent’s actions with regard to petitioner’s
discovery request and at the “Branerton conference”3 violated
2 Petitioner’s reported income was from withdrawals from an
individual retirement account.
3 Branerton Corp. v Commissioner, 61 T.C. 691 (1974), is
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