- 5 - 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 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011